Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Real estate development company advanced loans to its Indian subsidiary for funding step-down foreign subsidiaries undertaking real estate projects. Interest paid on loans borrowed for advancing such loans was allowed as business expenditure u/s 36(1)(iii). Subsidiary unable to realize interest from foreign subsidiaries due to financial distress and litigation between partners. Assessee decided not to charge interest to protect business interests and principal loan amount. Loans advanced for business purposes, hence interest paid on borrowings admissible u/s 36(1)(iii) despite no interest income during the year. Appellate Tribunal upheld order allowing deduction.
Real estate development company advanced loans to its Indian subsidiary for funding step-down foreign subsidiaries undertaking real estate projects. Interest paid on loans borrowed for advancing such loans was allowed as business expenditure u/s 36(1)(iii). Subsidiary unable to realize interest from foreign subsidiaries due to financial distress and litigation between partners. Assessee decided not to charge interest to protect business interests and principal loan amount. Loans advanced for business purposes, hence interest paid on borrowings admissible u/s 36(1)(iii) despite no interest income during the year. Appellate Tribunal upheld order allowing deduction.
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