Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Section 41(1) applies only where expenditure or a trading liability was previously allowed as a deduction and the taxpayer subsequently obtains a benefit through remission or cessation. Unpaid interest earlier disallowed under section 43B did not satisfy that condition. Continued balance-sheet recognition, with no write-back, waiver, settlement or discharge, also did not establish cessation; a lender's discounted assignment to an asset reconstruction company did not extinguish the debt. The addition was deleted. Depreciation remained available for a mortgaged building in an existing asset block because mortgage does not transfer ownership and no sale, discard, business unavailability or permanent closure was shown; depreciation was allowed.
Section 41(1) applies only where expenditure or a trading liability was previously allowed as a deduction and the taxpayer subsequently obtains a benefit through remission or cessation. Unpaid interest earlier disallowed under section 43B did not satisfy that condition. Continued balance-sheet recognition, with no write-back, waiver, settlement or discharge, also did not establish cessation; a lender's discounted assignment to an asset reconstruction company did not extinguish the debt. The addition was deleted. Depreciation remained available for a mortgaged building in an existing asset block because mortgage does not transfer ownership and no sale, discard, business unavailability or permanent closure was shown; depreciation was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
