Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
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Foreign-currency loans repayable in US dollars were benchmarked using LIBOR plus 300 basis points rather than a domestic lending rate, and that transfer-pricing direction was sustained. Under TNMM, comparables must satisfy functional and product comparability; sectorally distinct engineering services and aluminium-capacitor manufacturing entities were excluded. No arm's-length interest adjustment applied to delayed associated-enterprise receivables where no interest was charged to either associated or non-associated enterprises and transaction pricing already reflected margins. Expenditure relating to investments could not be disallowed where no exempt dividend income was received or receivable during the year. The assessee's and Revenue's appeals were dismissed.
Foreign-currency loans repayable in US dollars were benchmarked using LIBOR plus 300 basis points rather than a domestic lending rate, and that transfer-pricing direction was sustained. Under TNMM, comparables must satisfy functional and product comparability; sectorally distinct engineering services and aluminium-capacitor manufacturing entities were excluded. No arm's-length interest adjustment applied to delayed associated-enterprise receivables where no interest was charged to either associated or non-associated enterprises and transaction pricing already reflected margins. Expenditure relating to investments could not be disallowed where no exempt dividend income was received or receivable during the year. The assessee's and Revenue's appeals were dismissed.
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