Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Commodity-trading receivables written off as bad debts qualify for deduction where they were previously included in income and written off in the books; a possible future recovery does not justify disallowance. Characterising the transactions as speculative or the amount as capital investment does not displace fulfilment of those conditions. The bad-debt disallowance was deleted, subject to taxation of any later recovery in the year received. For windmill-profit deductions, head-office expenses and depreciation on common assets require factual examination of their components, use and allocation to eligible operations. That computation was remanded for fresh adjudication.
Commodity-trading receivables written off as bad debts qualify for deduction where they were previously included in income and written off in the books; a possible future recovery does not justify disallowance. Characterising the transactions as speculative or the amount as capital investment does not displace fulfilment of those conditions. The bad-debt disallowance was deleted, subject to taxation of any later recovery in the year received. For windmill-profit deductions, head-office expenses and depreciation on common assets require factual examination of their components, use and allocation to eligible operations. That computation was remanded for fresh adjudication.
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