Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Expenditure incurred by subsidiary company for overseeing and executing contracts entered by parent company cannot be considered as business loss of subsidiary. Subsidiary did not undertake its own business and expenses were not occasioned in process or for its business. Expenditure must be connected with or related to business carried on by assessee and profits and gains therein to allow loss. Holding and subsidiary are separate entities, expenditure pertaining to one cannot be claimed by other. For deduction u/s 37, prerequisites are expenditure incurred in respect of business carried on by assessee and spent wholly and exclusively for its own business. Expenditure incurred by subsidiary not in ordinary course of its business cannot be allowed as deduction.
Expenditure incurred by subsidiary company for overseeing and executing contracts entered by parent company cannot be considered as business loss of subsidiary. Subsidiary did not undertake its own business and expenses were not occasioned in process or for its business. Expenditure must be connected with or related to business carried on by assessee and profits and gains therein to allow loss. Holding and subsidiary are separate entities, expenditure pertaining to one cannot be claimed by other. For deduction u/s 37, prerequisites are expenditure incurred in respect of business carried on by assessee and spent wholly and exclusively for its own business. Expenditure incurred by subsidiary not in ordinary course of its business cannot be allowed as deduction.
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