Validity of faceless assessment procedure challenged for jurisdictional AO intervention mid-remand, resulting in quashing of assessment for procedural...
Inventory write-off and fraudulent/wrongful trading allegations in corporate insolvency led to director liability principles applied and appeal dismis...
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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