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...
Explanation 4 to section 11 prevents loan-funded expenditure from being treated as application of income when the borrowing is deployed, but permits the repayment to qualify in the year of repayment if that amount was not already allowed. On the record, the charitable trust had excluded borrowed sums from application in the years of borrowing and claimed application only on repayment, and the Revenue did not rebut the supporting accounts, returns or statements. As no earlier double claim was shown, the repayment was treated as valid application of income and the disallowance was deleted.
Explanation 4 to section 11 prevents loan-funded expenditure from being treated as application of income when the borrowing is deployed, but permits the repayment to qualify in the year of repayment if that amount was not already allowed. On the record, the charitable trust had excluded borrowed sums from application in the years of borrowing and claimed application only on repayment, and the Revenue did not rebut the supporting accounts, returns or statements. As no earlier double claim was shown, the repayment was treated as valid application of income and the disallowance was deleted.
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