Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Interest paid on delayed VAT was examined under the principle that business expenses must be incurred wholly and exclusively for business. Applying the precedent that interest on sales-tax arrears is compensatory rather than penal, the article concludes the assessing authorities erred in disallowing such interest; accordingly the interest debited in the profit and loss account should be allowed as a deductible business expenditure under section 37(1). The operative effect is allowance of the claimed deduction following the compensatory-interest characterisation.
Interest paid on delayed VAT was examined under the principle that business expenses must be incurred wholly and exclusively for business. Applying the precedent that interest on sales-tax arrears is compensatory rather than penal, the article concludes the assessing authorities erred in disallowing such interest; accordingly the interest debited in the profit and loss account should be allowed as a deductible business expenditure under section 37(1). The operative effect is allowance of the claimed deduction following the compensatory-interest characterisation.
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