Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
An appellate authority can entertain an alternate deduction claim even without a revised return where the claim is not a fresh item but a request to allow the same interest expenditure under the correct head, and the issue can be examined on existing material. The Tribunal rejected the Revenue's objection based on non-filing of a revised return and upheld admission of the claim in appeal. It also held that interest on borrowed funds remained deductible as business expenditure because the loan had been used for business and that factual finding was not displaced. The disallowance was therefore unsustainable and the Revenue's appeals failed.
An appellate authority can entertain an alternate deduction claim even without a revised return where the claim is not a fresh item but a request to allow the same interest expenditure under the correct head, and the issue can be examined on existing material. The Tribunal rejected the Revenue's objection based on non-filing of a revised return and upheld admission of the claim in appeal. It also held that interest on borrowed funds remained deductible as business expenditure because the loan had been used for business and that factual finding was not displaced. The disallowance was therefore unsustainable and the Revenue's appeals failed.
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