Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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