Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
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Expenditure on an abandoned towel-manufacturing expansion within an existing textile business was deductible as revenue expenditure because no completed capital asset or enduring advantage arose. Its initial classification as capital work-in-progress did not determine its character, which depended on its purpose and business context. The matching principle could not restrict a statutory deduction or compel spreading of expenditure; it applies only where the taxpayer elects to spread costs and the relevant conditions are met. The write-off was allowable in the relevant year, and the disallowance was deleted.
Expenditure on an abandoned towel-manufacturing expansion within an existing textile business was deductible as revenue expenditure because no completed capital asset or enduring advantage arose. Its initial classification as capital work-in-progress did not determine its character, which depended on its purpose and business context. The matching principle could not restrict a statutory deduction or compel spreading of expenditure; it applies only where the taxpayer elects to spread costs and the relevant conditions are met. The write-off was allowable in the relevant year, and the disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.