Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The note addresses tax deductibility of business expenses where liability crystallises in the relevant previous year but payment occurs later. It states the principle that expenses incurred wholly and exclusively for business are deductible in the year the liability crystallised; subsequent payment does not defeat deduction if records show liability and tax deducted at source. Applying this to compression and blasting expenses, the author concludes these expenses were business-related, liability had crystallised in the relevant previous year, and therefore deduction for the assessment year was justified.
The note addresses tax deductibility of business expenses where liability crystallises in the relevant previous year but payment occurs later. It states the principle that expenses incurred wholly and exclusively for business are deductible in the year the liability crystallised; subsequent payment does not defeat deduction if records show liability and tax deducted at source. Applying this to compression and blasting expenses, the author concludes these expenses were business-related, liability had crystallised in the relevant previous year, and therefore deduction for the assessment year was justified.
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