<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>Rs.66,00,000 treated as salary under Income-tax Act Section 15; professional income and interest disallowed for lack of nexus</title>
    <link>https://www.taxtmi.com/highlights?id=93997</link>
    <description>HC affirms AT and revenue findings, holding that receipt of Rs. 66,00,000 from the company constitutes salary, not professional/business income, because the assessee failed to produce documentary evidence specifying nature or nexus of professional/technical services rendered. The court found a conflict of interest where loans advanced to the company were in the assessee&#039;s name, undermining the professional-fee characterization; TDS treatment as &quot;professional charges&quot; is not determinative of income heads. Further, interest expenditure of Rs. 45,26,956 is disallowed for lack of nexus with any business or profession of the assessee; mortgaging and advancing personal property to the company does not render the interest an allowable business expense. Appeal dismissed; decision for Revenue.</description>
    <language>en-us</language>
    <pubDate>Sat, 08 Nov 2025 08:30:03 +0530</pubDate>
    <lastBuildDate>Sat, 08 Nov 2025 08:30:04 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=863207" rel="self" type="application/rss+xml"/>
    <item>
      <title>Rs.66,00,000 treated as salary under Income-tax Act Section 15; professional income and interest disallowed for lack of nexus</title>
      <link>https://www.taxtmi.com/highlights?id=93997</link>
      <description>HC affirms AT and revenue findings, holding that receipt of Rs. 66,00,000 from the company constitutes salary, not professional/business income, because the assessee failed to produce documentary evidence specifying nature or nexus of professional/technical services rendered. The court found a conflict of interest where loans advanced to the company were in the assessee&#039;s name, undermining the professional-fee characterization; TDS treatment as &quot;professional charges&quot; is not determinative of income heads. Further, interest expenditure of Rs. 45,26,956 is disallowed for lack of nexus with any business or profession of the assessee; mortgaging and advancing personal property to the company does not render the interest an allowable business expense. Appeal dismissed; decision for Revenue.</description>
      <category>Highlights</category>
      <law>Income Tax</law>
      <pubDate>Sat, 08 Nov 2025 08:30:03 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/highlights?id=93997</guid>
    </item>
  </channel>
</rss>