Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Interest on borrowed capital was held deductible as revenue expenditure because the Tribunal's binding factual finding showed the investments in subsidiary or joint venture concerns were made for business expansion and commercial expediency in the assessee's fertilizer business. The Revenue's contrary view was rejected, and the later remand on actual use of borrowed funds was treated as academic in light of that finding. On rectification, the Court held that a prior liberty to move the Tribunal did not oblige it to allow rectification; no mistake apparent from the record was shown, so dismissal of the miscellaneous petition was proper. The appeal was dismissed.
Interest on borrowed capital was held deductible as revenue expenditure because the Tribunal's binding factual finding showed the investments in subsidiary or joint venture concerns were made for business expansion and commercial expediency in the assessee's fertilizer business. The Revenue's contrary view was rejected, and the later remand on actual use of borrowed funds was treated as academic in light of that finding. On rectification, the Court held that a prior liberty to move the Tribunal did not oblige it to allow rectification; no mistake apparent from the record was shown, so dismissal of the miscellaneous petition was proper. The appeal was dismissed.
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