Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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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