https://www.taxtmi.com/caselaws?id=184062 The statutory word "paid" in the charge-on-income rules was given its ordinary legal meaning of discharge of the debt, so interest met by a genuine circular refinancing arrangement remained deductible even though the structure was pre-ordained and tax-motivated. The purposive Ramsay approach did not justify rewriting the language to deny effect to a real payment. Separately, a section 54 agreement fixed the taxpayer's liability for the year agreed, but it did not conclusively determine charges on income available for carry forward into later accounting periods, which remained subject to the separate statutory machinery. en-us Tue, 08 Feb 2000 00:00:00 +0530 Tue, 28 Jun 2016 17:59:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184062 The statutory word "paid" in the charge-on-income rules was given its ordinary legal meaning of discharge of the debt, so interest met by a genuine circular refinancing arrangement remained deductible even though the structure was pre-ordained and tax-motivated. The purposive Ramsay approach did not justify rewriting the language to deny effect to a real payment. Separately, a section 54 agreement fixed the taxpayer's liability for the year agreed, but it did not conclusively determine charges on income available for carry forward into later accounting periods, which remained subject to the separate statutory machinery. Case-Laws Income Tax Tue, 08 Feb 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184062