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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
