TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Interest on borrowings used to acquire or maintain controlling interests through strategic investments may qualify as business expenditure where the taxpayer's objects, investment pattern, conduct and disclosures establish that strategic investment is part of its business. The business-purpose requirement extends beyond immediate profit generation; dividend being taxed under another head or investments not producing direct business receipts does not by itself defeat deductibility where commercial expediency exists. Separately, where available interest-free funds exceed investments and interest-free advances, investments are presumed to have been made from those funds. Absence of a direct fund-wise nexus therefore does not justify disallowing interest on borrowings.
Interest on borrowings used to acquire or maintain controlling interests through strategic investments may qualify as business expenditure where the taxpayer's objects, investment pattern, conduct and disclosures establish that strategic investment is part of its business. The business-purpose requirement extends beyond immediate profit generation; dividend being taxed under another head or investments not producing direct business receipts does not by itself defeat deductibility where commercial expediency exists. Separately, where available interest-free funds exceed investments and interest-free advances, investments are presumed to have been made from those funds. Absence of a direct fund-wise nexus therefore does not justify disallowing interest on borrowings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4824 
Join Channel 
