Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
A partnership firm is a separate taxable entity under the Income-tax Act only from the date it comes into existence, so it cannot claim interest expenditure attributable to an earlier period when the business was still a proprietorship concern. The Tribunal held that the firm, having commenced on 15.06.2014, was entitled to deduct expenses only for its own period of existence and not for 01.04.2014 to 14.06.2014. The proportionate disallowance of interest made by the Assessing Officer and upheld in first appeal was therefore sustained. The delay in filing the appeal was condoned on sufficient cause.
A partnership firm is a separate taxable entity under the Income-tax Act only from the date it comes into existence, so it cannot claim interest expenditure attributable to an earlier period when the business was still a proprietorship concern. The Tribunal held that the firm, having commenced on 15.06.2014, was entitled to deduct expenses only for its own period of existence and not for 01.04.2014 to 14.06.2014. The proportionate disallowance of interest made by the Assessing Officer and upheld in first appeal was therefore sustained. The delay in filing the appeal was condoned on sufficient cause.
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