Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
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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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