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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Section 36(1)(iii) allows deduction of interest where the borrowing, the interest payment and use of capital for business are established, and the statutory phrase "for the purposes of business" is of wide import. The Court applied the test of commercial expediency, holding that interest need not be disallowed merely because borrowed funds were routed through a subsidiary or group concern, and it was not necessary that the advance should directly earn profits for the assessee. Accepting the Tribunal's view on the composite nature of the business and the business purpose of the borrowing, the Court held the interest on the bank loan to be allowable and set aside the High Court's contrary decision.
Section 36(1)(iii) allows deduction of interest where the borrowing, the interest payment and use of capital for business are established, and the statutory phrase "for the purposes of business" is of wide import. The Court applied the test of commercial expediency, holding that interest need not be disallowed merely because borrowed funds were routed through a subsidiary or group concern, and it was not necessary that the advance should directly earn profits for the assessee. Accepting the Tribunal's view on the composite nature of the business and the business purpose of the borrowing, the Court held the interest on the bank loan to be allowable and set aside the High Court's contrary decision.
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