Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Interest claimed on unsecured loans admitted to be bogus accommodation entries is treated as non-deductible as a consequential matter. The tax deducted at source component of such interest must be excluded from the disallowance. Estimated commission additions for obtaining accommodation entries require corroborative evidence of payment or a reliable basis for estimation; a presumption alone is insufficient. Accordingly, the interest disallowance is retained after excluding tax deducted at source, while the commission additions are deleted.
Interest claimed on unsecured loans admitted to be bogus accommodation entries is treated as non-deductible as a consequential matter. The tax deducted at source component of such interest must be excluded from the disallowance. Estimated commission additions for obtaining accommodation entries require corroborative evidence of payment or a reliable basis for estimation; a presumption alone is insufficient. Accordingly, the interest disallowance is retained after excluding tax deducted at source, while the commission additions are deleted.
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