Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Interest on capital borrowed for business purposes is deductible, subject to the restriction applicable until an acquired asset is first put to use. Use of land as a storage yard may be established through delivery and transport records, electricity bills and photographs; such evidence requires verification and cannot be rejected without contrary material. Construction reflected as capital work-in-progress on part of the land does not by itself show that the remaining land was not used for business. Where interest-free funds and borrowings form a common pool, investment is presumed to come from interest-free funds unless a direct nexus with interest-bearing borrowings is established.
Interest on capital borrowed for business purposes is deductible, subject to the restriction applicable until an acquired asset is first put to use. Use of land as a storage yard may be established through delivery and transport records, electricity bills and photographs; such evidence requires verification and cannot be rejected without contrary material. Construction reflected as capital work-in-progress on part of the land does not by itself show that the remaining land was not used for business. Where interest-free funds and borrowings form a common pool, investment is presumed to come from interest-free funds unless a direct nexus with interest-bearing borrowings is established.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
