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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Expenditure incurred to implement a contractual closure of a business undertaking is not deductible under section 37(1), as that provision requires expenditure wholly and exclusively incurred for carrying on business rather than bringing an undertaking to an end. Common management of the closed and continuing divisions does not satisfy this requirement; the closure-payment disallowance was therefore restored. Foreign exchange fluctuation on imports must be determined from actual liabilities under individual transactions where book figures are available. As the fluctuation on capital goods had been capitalised and the claimed loss related to spares and consumables, with no contrary Revenue evidence, the estimated disallowance was unsustainable and its deletion was upheld.
Expenditure incurred to implement a contractual closure of a business undertaking is not deductible under section 37(1), as that provision requires expenditure wholly and exclusively incurred for carrying on business rather than bringing an undertaking to an end. Common management of the closed and continuing divisions does not satisfy this requirement; the closure-payment disallowance was therefore restored. Foreign exchange fluctuation on imports must be determined from actual liabilities under individual transactions where book figures are available. As the fluctuation on capital goods had been capitalised and the claimed loss related to spares and consumables, with no contrary Revenue evidence, the estimated disallowance was unsustainable and its deletion was upheld.
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