Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Recurring annual maintenance charges for optical fibre network usage were treated as revenue expenditure, while upfront connectivity fees were to be amortised on a straight-line basis over the relevant 15-year contractual term, subject to agreement-wise verification. For exempt-income disallowance, own funds in excess of investments and use of borrowed funds for business supported denial of interest disallowance; administrative disallowance was confined to investments yielding exempt income and capped by exempt income earned. The text also notes that broadband network acquisition rights, goodwill arising on amalgamation, and non-compete fee can qualify as depreciable intangible assets, and that appellate authorities may entertain additional claims when facts are already on record.
Recurring annual maintenance charges for optical fibre network usage were treated as revenue expenditure, while upfront connectivity fees were to be amortised on a straight-line basis over the relevant 15-year contractual term, subject to agreement-wise verification. For exempt-income disallowance, own funds in excess of investments and use of borrowed funds for business supported denial of interest disallowance; administrative disallowance was confined to investments yielding exempt income and capped by exempt income earned. The text also notes that broadband network acquisition rights, goodwill arising on amalgamation, and non-compete fee can qualify as depreciable intangible assets, and that appellate authorities may entertain additional claims when facts are already on record.
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