Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
Transfer pricing rules require benchmarking the actual international transaction and generally prohibit re-characterising legally valid compulsorily convertible debentures as equity merely because another commercial structure appears preferable. Compulsory conversion, lack of repayment before conversion, and separate regulatory or accounting treatment do not alter their debt character until conversion. The nil arm's length price for interest was therefore set aside, with fresh benchmarking required using CUP or another permissible method. Bad debts written off are deductible where statutory conditions are met and debtor accounts are correspondingly extinguished; independent proof of irrecoverability is unnecessary. The bad-debt disallowance was deleted.
Transfer pricing rules require benchmarking the actual international transaction and generally prohibit re-characterising legally valid compulsorily convertible debentures as equity merely because another commercial structure appears preferable. Compulsory conversion, lack of repayment before conversion, and separate regulatory or accounting treatment do not alter their debt character until conversion. The nil arm's length price for interest was therefore set aside, with fresh benchmarking required using CUP or another permissible method. Bad debts written off are deductible where statutory conditions are met and debtor accounts are correspondingly extinguished; independent proof of irrecoverability is unnecessary. The bad-debt disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.