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...
Deduction of interest expenditure incurred on borrowed funds u/s 57 - Interest incurred on borrowed funds utilized for making investment in shares in company of Singapore - The ITAT considered the purpose of the investment, emphasizing that the investment was made to earn future income. It referred to a similar case decided by the Calcutta High Court, which held that expenditure on interest could be allowable under Section 57 even if the investment was not solely for earning dividends. The Tribunal concluded that since the investment was made to generate income, the interest expenditure should be allowed as a deduction.
Deduction of interest expenditure incurred on borrowed funds u/s 57 - Interest incurred on borrowed funds utilized for making investment in shares in company of Singapore - The ITAT considered the purpose of the investment, emphasizing that the investment was made to earn future income. It referred to a similar case decided by the Calcutta High Court, which held that expenditure on interest could be allowable under Section 57 even if the investment was not solely for earning dividends. The Tribunal concluded that since the investment was made to generate income, the interest expenditure should be allowed as a deduction.
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