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...
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The case involves the disallowance of expenditure incurred during business setup. The Appellate Tribunal clarified that setup of business is distinct from commencement of business. Expenses post-setup are allowable even if no revenue is generated. The gestation period for business like the assessee's is long. The Tribunal held that actual business income generation is not essential for claiming business expenditure, focusing on whether the business is set-up. The Tribunal allowed revenue expenditure claimed post-setup date. Depreciation was allowed based on setup date. Disallowance of bonus under u/s 43B/36 was overturned as bonus is part of CTC and not profits. Addition on Short-Term Capital Gains was upheld as gains were offered under 'income from other sources' not as capital gains.
The case involves the disallowance of expenditure incurred during business setup. The Appellate Tribunal clarified that setup of business is distinct from commencement of business. Expenses post-setup are allowable even if no revenue is generated. The gestation period for business like the assessee's is long. The Tribunal held that actual business income generation is not essential for claiming business expenditure, focusing on whether the business is set-up. The Tribunal allowed revenue expenditure claimed post-setup date. Depreciation was allowed based on setup date. Disallowance of bonus under u/s 43B/36 was overturned as bonus is part of CTC and not profits. Addition on Short-Term Capital Gains was upheld as gains were offered under 'income from other sources' not as capital gains.
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