Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Related-party interest expenditure may be disallowed only to the extent it is excessive compared with fair market value; where the interest on an unsecured related-party loan is not excessive, the related expenditure is not disallowable. The provision does not permit a corresponding adjustment by taxing notional interest income from a related party, and separate loan and current accounts cannot be consolidated merely because they involve the same party. Employees' PF and ESI contributions paid after the prescribed due date remain disallowable. Claims for related-party software services, maintenance and brokerage require adequate evidence of the services or facilitation actually provided; unsupported claims fail the genuineness test.
Related-party interest expenditure may be disallowed only to the extent it is excessive compared with fair market value; where the interest on an unsecured related-party loan is not excessive, the related expenditure is not disallowable. The provision does not permit a corresponding adjustment by taxing notional interest income from a related party, and separate loan and current accounts cannot be consolidated merely because they involve the same party. Employees' PF and ESI contributions paid after the prescribed due date remain disallowable. Claims for related-party software services, maintenance and brokerage require adequate evidence of the services or facilitation actually provided; unsupported claims fail the genuineness test.
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