Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Assessees treatment of project selling costs under the percentage completion method conformed with ICAI guidance; advertising, promotion and commission expenses were allowable as revenue expenditure since revenue recognition threshold was not met. Interest on debentures financing the project must be capitalized; AO directed to disallow interest expense claimed without nexus to other uses. Debenture issue expenditure held allowable as borrowing cost. Notional interest on interest-free advances to related parties to be recalculated using assessees cost of capital and cannot increase claimed interest; AO to restrict adjustment to actual claimed interest. Section 14A adjustment partly allowed; TDS disallowance deleted due to excess timely deposit and AOs reverse calculation rejected.
Assessees treatment of project selling costs under the percentage completion method conformed with ICAI guidance; advertising, promotion and commission expenses were allowable as revenue expenditure since revenue recognition threshold was not met. Interest on debentures financing the project must be capitalized; AO directed to disallow interest expense claimed without nexus to other uses. Debenture issue expenditure held allowable as borrowing cost. Notional interest on interest-free advances to related parties to be recalculated using assessees cost of capital and cannot increase claimed interest; AO to restrict adjustment to actual claimed interest. Section 14A adjustment partly allowed; TDS disallowance deleted due to excess timely deposit and AOs reverse calculation rejected.
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