Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Interest expenditure on borrowings used to make interest-bearing unsecured advances is deductible against taxable interest income under section 57 where the nexus is established. The Assessing Officer's findings showed that the advances to private parties were funded through interest-bearing loans from banks and non-banking financial companies. As the borrowing cost was directly connected with earning the interest income assessed under income from other sources, the disallowance was deleted for the relevant assessment years.
Interest expenditure on borrowings used to make interest-bearing unsecured advances is deductible against taxable interest income under section 57 where the nexus is established. The Assessing Officer's findings showed that the advances to private parties were funded through interest-bearing loans from banks and non-banking financial companies. As the borrowing cost was directly connected with earning the interest income assessed under income from other sources, the disallowance was deleted for the relevant assessment years.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
