https://www.taxtmi.com/article/detailed?id=6387 The central issue is whether royalty payments computed in accordance with government notifications and communications under the Oilfield regulatory framework can be disallowed as unlawful under the Explanation to Section 37. Where payments to the State are made pursuant to statutory authorization and executive direction, and all other statutory ingredients of business expenditure are present, such payments warrant scrutiny before being treated as non deductible; arm's length pricing considerations may assist reasonableness assessments. The article also criticises revenue practice of pursuing appeals on fact based findings despite administrative guidance to avoid unnecessary litigation. en-us Mon, 17 Aug 2015 06:48:18 +0530 Mon, 17 Aug 2015 06:48:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=6387 The central issue is whether royalty payments computed in accordance with government notifications and communications under the Oilfield regulatory framework can be disallowed as unlawful under the Explanation to Section 37. Where payments to the State are made pursuant to statutory authorization and executive direction, and all other statutory ingredients of business expenditure are present, such payments warrant scrutiny before being treated as non deductible; arm's length pricing considerations may assist reasonableness assessments. The article also criticises revenue practice of pursuing appeals on fact based findings despite administrative guidance to avoid unnecessary litigation. Articles Income Tax Mon, 17 Aug 2015 06:48:18 +0530 https://www.taxtmi.com/article/detailed?id=6387