Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Allowable revenue expenditure u/s 37(1) - Writing off of advance given to the Director - waiver of excess remuneration paid to the Director - The provisions of Section 37(1) clearly set out that once the proper approval has been taken the writing off advance recoverable cannot be disallowed. It is a genuine business expenses, the additions made by the AO cannot be said to be in the nature of capital expenditure, since no enduring benefit accrues or arises to the assessee from advancing loan to the MD. Thus, the same accordingly acquires character of revenue expenditure. - AT
Allowable revenue expenditure u/s 37(1) - Writing off of advance given to the Director - waiver of excess remuneration paid to the Director - The provisions of Section 37(1) clearly set out that once the proper approval has been taken the writing off advance recoverable cannot be disallowed. It is a genuine business expenses, the additions made by the AO cannot be said to be in the nature of capital expenditure, since no enduring benefit accrues or arises to the assessee from advancing loan to the MD. Thus, the same accordingly acquires character of revenue expenditure. - AT
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