Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Interest on borrowed funds may not be disallowed where an assessee can demonstrate sufficient own interest-free funds for interest-free advances to related concerns. Where borrowed funds are diverted to associates, the allowability of interest must be examined by comparing interest paid on borrowings with interest charged on the advances, and the differential cost of diverted funds can be disallowed. Advances to directors and key managerial personnel require proof of commercial expediency; absent such evidence, proportionate interest attributable to those advances is liable to disallowance under section 36(1)(iii).
Interest on borrowed funds may not be disallowed where an assessee can demonstrate sufficient own interest-free funds for interest-free advances to related concerns. Where borrowed funds are diverted to associates, the allowability of interest must be examined by comparing interest paid on borrowings with interest charged on the advances, and the differential cost of diverted funds can be disallowed. Advances to directors and key managerial personnel require proof of commercial expediency; absent such evidence, proportionate interest attributable to those advances is liable to disallowance under section 36(1)(iii).
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