Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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