Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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