Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
The article analyses an appellate tribunal decision rejecting a unilateral loan write off to a wholly owned subsidiary as a deductible bad debt or business loss, applying transfer pricing principles and surrounding circumstance tests to sustain a transfer pricing adjustment and disallow the write off for lack of commercial substance. It finds weighted R&D deduction unavailable for want of mandatory administrative concurrence, but accepts the same expenditures as ordinary business expenditure. An ad hoc apportionment denying an industrial undertaking deduction was deleted under the consistency principle. Imputed interest on interest free advances was deleted on proof of interest free funds.
The article analyses an appellate tribunal decision rejecting a unilateral loan write off to a wholly owned subsidiary as a deductible bad debt or business loss, applying transfer pricing principles and surrounding circumstance tests to sustain a transfer pricing adjustment and disallow the write off for lack of commercial substance. It finds weighted R&D deduction unavailable for want of mandatory administrative concurrence, but accepts the same expenditures as ordinary business expenditure. An ad hoc apportionment denying an industrial undertaking deduction was deleted under the consistency principle. Imputed interest on interest free advances was deleted on proof of interest free funds.
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TaxTMI 
TaxTMI 
