Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Claim of Loss - Deduction u/s. 57 - Taxability of real income / net interest income - The Tribunal observed that the investment in perpetual debt instruments (PDIs) was financed by secured debentures. It was established that the funds raised through debentures were not meant for investment in PDIs but for the objectives of the company. The Tribunal allowed the deduction of interest expenditure against interest income, considering only the net income liable for taxation. - ITAT emphasized that only real income, subject to the provisions of the Act, is taxable.
Claim of Loss - Deduction u/s. 57 - Taxability of real income / net interest income - The Tribunal observed that the investment in perpetual debt instruments (PDIs) was financed by secured debentures. It was established that the funds raised through debentures were not meant for investment in PDIs but for the objectives of the company. The Tribunal allowed the deduction of interest expenditure against interest income, considering only the net income liable for taxation. - ITAT emphasized that only real income, subject to the provisions of the Act, is taxable.
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