Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Interest paid on delayed VAT was examined under the principle that business expenses must be incurred wholly and exclusively for business. Applying the precedent that interest on sales-tax arrears is compensatory rather than penal, the article concludes the assessing authorities erred in disallowing such interest; accordingly the interest debited in the profit and loss account should be allowed as a deductible business expenditure under section 37(1). The operative effect is allowance of the claimed deduction following the compensatory-interest characterisation.
Interest paid on delayed VAT was examined under the principle that business expenses must be incurred wholly and exclusively for business. Applying the precedent that interest on sales-tax arrears is compensatory rather than penal, the article concludes the assessing authorities erred in disallowing such interest; accordingly the interest debited in the profit and loss account should be allowed as a deductible business expenditure under section 37(1). The operative effect is allowance of the claimed deduction following the compensatory-interest characterisation.
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