Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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Surplus interest-free funds support a presumption that investments were funded from those sources, where such funds exceed the investments. On that basis, interest expenditure could not be disallowed or capitalised as capital work in progress when the building had already been put to use in earlier years. The text also states that a disallowance computed under section 14A read with rule 8D cannot, merely for that reason, be added to book profit under section 115JB. It records that the appellate deletions were upheld, as the issues were covered by binding decisions and concurrent factual findings, with no substantial question of law arising.
Surplus interest-free funds support a presumption that investments were funded from those sources, where such funds exceed the investments. On that basis, interest expenditure could not be disallowed or capitalised as capital work in progress when the building had already been put to use in earlier years. The text also states that a disallowance computed under section 14A read with rule 8D cannot, merely for that reason, be added to book profit under section 115JB. It records that the appellate deletions were upheld, as the issues were covered by binding decisions and concurrent factual findings, with no substantial question of law arising.
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