Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Tax was deductible at source on annual lease rent paid to development authorities, and the exemption under section 10(20A) did not apply. Interest for delayed deduction was confined to the period from when tax became deductible until the deductee filed its return. Interest expenditure capitalised as work-in-progress and not charged to the profit and loss account could not be disallowed for delayed tax deduction, because disallowance applies only to expenditure claimed in the profit and loss account. Accordingly, the disallowance of capitalised interest was deleted, while the tax-deduction liability on annual lease rent remained.
Tax was deductible at source on annual lease rent paid to development authorities, and the exemption under section 10(20A) did not apply. Interest for delayed deduction was confined to the period from when tax became deductible until the deductee filed its return. Interest expenditure capitalised as work-in-progress and not charged to the profit and loss account could not be disallowed for delayed tax deduction, because disallowance applies only to expenditure claimed in the profit and loss account. Accordingly, the disallowance of capitalised interest was deleted, while the tax-deduction liability on annual lease rent remained.
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