Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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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