Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Deduction of rent expenditure was denied because the assessee failed to prove that the new premises were used for business during the relevant AY. Although a rent agreement and an application to shift the excise licence were produced, business use was legally contingent on excise permission and issuance of a new licence, which were granted only in the subsequent AY; without such permission, the assessee could not have shifted operations, and the premises could not be treated as used for business in the year under consideration. The disallowance was therefore sustained and the appeal was dismissed. - HC
Deduction of rent expenditure was denied because the assessee failed to prove that the new premises were used for business during the relevant AY. Although a rent agreement and an application to shift the excise licence were produced, business use was legally contingent on excise permission and issuance of a new licence, which were granted only in the subsequent AY; without such permission, the assessee could not have shifted operations, and the premises could not be treated as used for business in the year under consideration. The disallowance was therefore sustained and the appeal was dismissed. - HC
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