Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Interest expenditure may be deducted against dividend income only to the extent that borrowed funds have a direct nexus with investments generating that income; the extent of such nexus is a factual determination and the balance interest cannot be deducted without supporting evidence. No notional interest is taxable on refundable security deposits for employee residential premises where the deposits serve business purposes and generate no actual income. The High Court also rejected the Revenue's challenges concerning deduction for a new industrial undertaking in existing factory premises and interest and trial-run overheads relating to new machinery, following prior decisions. Questions on closing-stock valuation, including excise-duty treatment, were answered under an earlier High Court ruling.
Interest expenditure may be deducted against dividend income only to the extent that borrowed funds have a direct nexus with investments generating that income; the extent of such nexus is a factual determination and the balance interest cannot be deducted without supporting evidence. No notional interest is taxable on refundable security deposits for employee residential premises where the deposits serve business purposes and generate no actual income. The High Court also rejected the Revenue's challenges concerning deduction for a new industrial undertaking in existing factory premises and interest and trial-run overheads relating to new machinery, following prior decisions. Questions on closing-stock valuation, including excise-duty treatment, were answered under an earlier High Court ruling.
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