Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Strict construction of customs exemptions denied concession for brake components, while limitation restricted differential duty to timely Bills of Ent...
Page of 4913
Press 'Enter' after typing page number.
1281 to 1300 of 98250 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Section 263 revision was sustained for fresh examination of interest capitalisation because the actual use of external commercial borrowings for working capital was not demonstrated and the Assessing Officer had made no enquiry; a board resolution stating the borrowing purpose was insufficient. Revision could not, however, reopen matters already examined or direct unfocused verification. Directions concerning tax deduction on interest paid to Government authorities were deleted as they amounted to a fishing or roving enquiry without an identified assessment error. Re-examination of miscellaneous expenditure and service-provider charges was also deleted because the Assessing Officer had examined the evidence and adopted a plausible view, including on the treaty's make available clause.
Section 263 revision was sustained for fresh examination of interest capitalisation because the actual use of external commercial borrowings for working capital was not demonstrated and the Assessing Officer had made no enquiry; a board resolution stating the borrowing purpose was insufficient. Revision could not, however, reopen matters already examined or direct unfocused verification. Directions concerning tax deduction on interest paid to Government authorities were deleted as they amounted to a fishing or roving enquiry without an identified assessment error. Re-examination of miscellaneous expenditure and service-provider charges was also deleted because the Assessing Officer had examined the evidence and adopted a plausible view, including on the treaty's make available clause.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
