Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Input tax credit on QIP-related services was held admissible only to the extent the funds were used for repayment or pre-payment of borrowings, because that deployment was treated as business-related and incidental to operations under Section 16(1). The authority linked the tax credit test to the actual use of the QIP proceeds, finding a sufficient nexus where the funds reduced financial liabilities, improved liquidity, and supported business activity. By contrast, credit was denied on the portion used to invest in a wholly owned subsidiary, because the investment was an acquisition of securities by a distinct legal entity and did not create the direct nexus required with the appellant's own business.
Input tax credit on QIP-related services was held admissible only to the extent the funds were used for repayment or pre-payment of borrowings, because that deployment was treated as business-related and incidental to operations under Section 16(1). The authority linked the tax credit test to the actual use of the QIP proceeds, finding a sufficient nexus where the funds reduced financial liabilities, improved liquidity, and supported business activity. By contrast, credit was denied on the portion used to invest in a wholly owned subsidiary, because the investment was an acquisition of securities by a distinct legal entity and did not create the direct nexus required with the appellant's own business.
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