Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
Commercial expediency of interest-free advances to a wholly owned subsidiary should be assessed from the perspective of a prudent businessman, without substituting the Revenue's commercial judgment. The note addresses deduction of interest on borrowed funds advanced to a special purpose vehicle formed to acquire land for group business operations. Documentary evidence of the subsidiary's land-acquisition purpose, subsequent lease of the land for the proposed business, and a board-approved start-up interest holiday supports the business purpose of the advance. Delay in completing land-acquisition formalities does not, by itself, negate that purpose. Interest expenditure under section 36(1)(iii) is described as allowable, with the disallowance deleted.
Commercial expediency of interest-free advances to a wholly owned subsidiary should be assessed from the perspective of a prudent businessman, without substituting the Revenue's commercial judgment. The note addresses deduction of interest on borrowed funds advanced to a special purpose vehicle formed to acquire land for group business operations. Documentary evidence of the subsidiary's land-acquisition purpose, subsequent lease of the land for the proposed business, and a board-approved start-up interest holiday supports the business purpose of the advance. Delay in completing land-acquisition formalities does not, by itself, negate that purpose. Interest expenditure under section 36(1)(iii) is described as allowable, with the disallowance deleted.
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