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...
Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Eligible-industrial-unit deductions are discussed in relation to interest on staff advances and deposits, overdue customer-bill interest, and a Sikkim manufacturing unit. The notes distinguish interest not eligible for deduction from overdue-bill interest and address continuity where prior-year positions govern. They also cover exempt-income expenditure: sufficient interest-free own funds may preclude interest disallowance, while administrative expenditure is computed under the prescribed method. For LLP-interest transfers, partnership rights are capital assets, but related-party status and approved valuation require examination. In book-profit computation, the notes address exempt-income adjustments, intangible-asset amortisation, and treatment of a debenture redemption provision as an ascertained liability. They also explain appellate power to admit a lawful omitted claim evident from the record.
Eligible-industrial-unit deductions are discussed in relation to interest on staff advances and deposits, overdue customer-bill interest, and a Sikkim manufacturing unit. The notes distinguish interest not eligible for deduction from overdue-bill interest and address continuity where prior-year positions govern. They also cover exempt-income expenditure: sufficient interest-free own funds may preclude interest disallowance, while administrative expenditure is computed under the prescribed method. For LLP-interest transfers, partnership rights are capital assets, but related-party status and approved valuation require examination. In book-profit computation, the notes address exempt-income adjustments, intangible-asset amortisation, and treatment of a debenture redemption provision as an ascertained liability. They also explain appellate power to admit a lawful omitted claim evident from the record.
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