https://www.taxtmi.com/caselaws?id=58060 The Tribunal upheld the disallowance of a payment made by an assessee company to another company holding substantial interest, under section 40(c)(i) of the Income-tax Act, 1961. It ruled that the term 'person who has substantial interest in the company' includes entities like companies, not limited to living individuals. Despite conflicting Tribunal decisions, the statutory definitions supported the inclusion of companies within this provision, justifying the disallowance and emphasizing the broader interpretation of 'person' in tax matters. The appeal was dismissed, affirming the disallowance based on the recipient company's substantial interest in the payer company. en-us Tue, 31 Dec 1985 00:00:00 +0530 Fri, 17 Dec 2010 11:29:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58060 The Tribunal upheld the disallowance of a payment made by an assessee company to another company holding substantial interest, under section 40(c)(i) of the Income-tax Act, 1961. It ruled that the term 'person who has substantial interest in the company' includes entities like companies, not limited to living individuals. Despite conflicting Tribunal decisions, the statutory definitions supported the inclusion of companies within this provision, justifying the disallowance and emphasizing the broader interpretation of 'person' in tax matters. The appeal was dismissed, affirming the disallowance based on the recipient company's substantial interest in the payer company. Case-Laws Income Tax Tue, 31 Dec 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58060