https://www.taxtmi.com/caselaws?id=471064 Interest-free or inadequately remunerated loans to a concern connected with a person specified under Section 13(3) constitute a benefit attracting Sections 13(1)(c) and 13(1)(d). Under Section 164(2), the applicable CBDT circular and judicial position, the breach taxes only income attributable to the prohibited benefit at the maximum marginal rate, rather than withdrawing Section 11 exemption from the trust's entire income. Accordingly, notional interest on the connected-party loan is taxable, while the trust retains exemption for its remaining income. The Finance Act 2022 amendment to Section 13 is consistent with this limited-denial approach. en-us Wed, 09 Oct 2024 00:00:00 +0530 Wed, 19 Aug 2026 18:58:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471064 Interest-free or inadequately remunerated loans to a concern connected with a person specified under Section 13(3) constitute a benefit attracting Sections 13(1)(c) and 13(1)(d). Under Section 164(2), the applicable CBDT circular and judicial position, the breach taxes only income attributable to the prohibited benefit at the maximum marginal rate, rather than withdrawing Section 11 exemption from the trust's entire income. Accordingly, notional interest on the connected-party loan is taxable, while the trust retains exemption for its remaining income. The Finance Act 2022 amendment to Section 13 is consistent with this limited-denial approach. Case-Laws Income Tax Wed, 09 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471064