Arm's length pricing of bagasse transferred from a sugar...

Arm's length pricing of bagasse transferred from a sugar division to a power division may be supported by market quotations, an electricity tariff price adjusted for the relevant year and a valuation based on the fair and remunerative price of sugarcane; a regulatory fuel price is not necessarily determinative. Irrecoverable advances paid to vendors of a wholly owned subsidiary may qualify as business expenditure where the subsidiary extends the taxpayer's business and the payments serve that business. Direct payment and classification as loans do not by themselves negate commercial expediency. Harvesting and transportation payments forming part of sugarcane purchase costs and deducted from amounts payable to farmers do not attract tax deduction under Section 194C. If they are not part of the purchase cost, a claim that tax was deducted requires verification.