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...
Interest credited under a partnership deed may be allowable when calculated on daily running credit balances, even if opening and closing capital-account balances are debit balances and the credit is recorded through year-end journal entries under the mercantile system. The notes state that detailed account workings, contractual authorisation, recipient income recognition and tax deduction at source negate allegations of fictitious expenditure or income diversion; the related disallowance was deleted. Interest expenditure credited to a lender is also described as not disallowable where Form 16A evidences tax deduction and the recipient has recognised and returned the income; banking-channel payment is not stated to be required for accrued interest. The appeal was partly allowed.
Interest credited under a partnership deed may be allowable when calculated on daily running credit balances, even if opening and closing capital-account balances are debit balances and the credit is recorded through year-end journal entries under the mercantile system. The notes state that detailed account workings, contractual authorisation, recipient income recognition and tax deduction at source negate allegations of fictitious expenditure or income diversion; the related disallowance was deleted. Interest expenditure credited to a lender is also described as not disallowable where Form 16A evidences tax deduction and the recipient has recognised and returned the income; banking-channel payment is not stated to be required for accrued interest. The appeal was partly allowed.
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