Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The Tribunal upheld deletion of the section 14A disallowance, holding that interest-free surplus funds covered the investments and that administrative disallowance could not exceed the consistent 2% approach followed in earlier years. It also sustained treatment of professional fees as revenue expenditure, finding they supported existing business expansion without creating a capital asset or enduring advantage. The bad debt write-off was allowed because post-amendment section 36(1)(vii) requires only an actual write-off in the accounts. Payment for public relation services was held deductible on proof of commercial expediency and receipt of services. Deduction under section 80IA for the captive incinerator facility was sustained on market-value basis and consistency. Interest under section 234A was left for factual verification of timely filing.
The Tribunal upheld deletion of the section 14A disallowance, holding that interest-free surplus funds covered the investments and that administrative disallowance could not exceed the consistent 2% approach followed in earlier years. It also sustained treatment of professional fees as revenue expenditure, finding they supported existing business expansion without creating a capital asset or enduring advantage. The bad debt write-off was allowed because post-amendment section 36(1)(vii) requires only an actual write-off in the accounts. Payment for public relation services was held deductible on proof of commercial expediency and receipt of services. Deduction under section 80IA for the captive incinerator facility was sustained on market-value basis and consistency. Interest under section 234A was left for factual verification of timely filing.
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