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...
A bona fide change from the mercantile to the cash system for interest on loans may be permissible where it serves a legitimate purpose, is consistently followed, duly disclosed, and is not intended to avoid or reduce tax liability. The notes state that financial distress of the borrower and non-receipt of accrued interest supported the change, while the Revenue produced no material showing lack of legitimacy or frequent switching of methods. As the assessment record acknowledged use of the cash method, the change was treated as disclosed, and the addition for accrued but unrealised interest was deleted.
A bona fide change from the mercantile to the cash system for interest on loans may be permissible where it serves a legitimate purpose, is consistently followed, duly disclosed, and is not intended to avoid or reduce tax liability. The notes state that financial distress of the borrower and non-receipt of accrued interest supported the change, while the Revenue produced no material showing lack of legitimacy or frequent switching of methods. As the assessment record acknowledged use of the cash method, the change was treated as disclosed, and the addition for accrued but unrealised interest was deleted.
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