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 earned on fixed deposits kept only to furnish a bank guarantee for the project was held to have an inextricable nexus with the project and, therefore, had to be capitalised to work-in-progress rather than taxed as income from other sources. The Tribunal found the deposits were not a deployment of surplus funds, the bank guarantee remained in force during the relevant year, and the project had not finally ceased because cancellation was still under challenge. On that basis, it applied the project-linked receipt principle and distinguished Tuticorin Alkali, deleting the addition.
Interest earned on fixed deposits kept only to furnish a bank guarantee for the project was held to have an inextricable nexus with the project and, therefore, had to be capitalised to work-in-progress rather than taxed as income from other sources. The Tribunal found the deposits were not a deployment of surplus funds, the bank guarantee remained in force during the relevant year, and the project had not finally ceased because cancellation was still under challenge. On that basis, it applied the project-linked receipt principle and distinguished Tuticorin Alkali, deleting the addition.
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