Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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Advances written off may be deductible as business loss where they are made in the ordinary course of business and have a direct nexus with business operations. The Tribunal held that the balance security deposit paid for restaurant premises was a revenue loss because it was advanced for hotel business purposes and remained unrecovered after failed efforts to recover it. It also held that earnest money furnished for joint bidding to secure natural gas for hotel use was a business advance and its forfeiture was allowable as business loss. However, a write-off to an individual treated as a friendly loan, unsupported by evidence of any trade-related purpose, was not deductible and remained disallowed.
Advances written off may be deductible as business loss where they are made in the ordinary course of business and have a direct nexus with business operations. The Tribunal held that the balance security deposit paid for restaurant premises was a revenue loss because it was advanced for hotel business purposes and remained unrecovered after failed efforts to recover it. It also held that earnest money furnished for joint bidding to secure natural gas for hotel use was a business advance and its forfeiture was allowable as business loss. However, a write-off to an individual treated as a friendly loan, unsupported by evidence of any trade-related purpose, was not deductible and remained disallowed.
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