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Corporate guarantee furnished to an associated enterprise was treated as a separate international transaction, not a shareholder activity, and the 1% guarantee fee was upheld as arm's length on an internal CUP based on fees charged to other associated enterprises. The bad debt disallowance was deleted because, after the statutory amendment, the assessee need not prove actual irrecoverability once the debt is written off as irrecoverable in the accounts. Lease rentals in a finance lease were also held deductible as revenue expenditure, since book capitalization under AS-19 does not govern tax treatment and depreciation belongs to the legal owner, the lessor.
Corporate guarantee furnished to an associated enterprise was treated as a separate international transaction, not a shareholder activity, and the 1% guarantee fee was upheld as arm's length on an internal CUP based on fees charged to other associated enterprises. The bad debt disallowance was deleted because, after the statutory amendment, the assessee need not prove actual irrecoverability once the debt is written off as irrecoverable in the accounts. Lease rentals in a finance lease were also held deductible as revenue expenditure, since book capitalization under AS-19 does not govern tax treatment and depreciation belongs to the legal owner, the lessor.
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