Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
ITAT held that where interest on unsecured loans was genuinely incurred for business purposes, the dispute could be confined only to the year of allowability under the mercantile system. As no finding was recorded that the interest was bogus, non-business, or lacking bona fides, disallowance of the portion claimed in the relevant year could not be sustained merely because it might be deductible in the next year. Shifting the deduction period was treated as revenue neutral, and the addition for alleged excess interest expenditure was deleted.
ITAT held that where interest on unsecured loans was genuinely incurred for business purposes, the dispute could be confined only to the year of allowability under the mercantile system. As no finding was recorded that the interest was bogus, non-business, or lacking bona fides, disallowance of the portion claimed in the relevant year could not be sustained merely because it might be deductible in the next year. Shifting the deduction period was treated as revenue neutral, and the addition for alleged excess interest expenditure was deleted.
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