Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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