Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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