https://www.taxtmi.com/caselaws?id=341086 Amounts advanced in the ordinary course of business to support a wholly owned overseas subsidiary were treated as deductible business loss or revenue expenditure when the venture was discontinued and the write-off was non-capital in nature. The analysis turned on commercial expediency: the subsidiary was set up to further the assessee's business interests and sourced goods exclusively from the assessee, so the advances formed part of the assessee's business operations. The recipient's treatment of the funds as capital or quasi-equity did not determine deductibility in the assessee's hands. On that reasoning, the disallowance was unsustainable and the write-off was allowable. en-us Fri, 24 Mar 2017 00:00:00 +0530 Sat, 01 Apr 2017 09:31:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=341086 Amounts advanced in the ordinary course of business to support a wholly owned overseas subsidiary were treated as deductible business loss or revenue expenditure when the venture was discontinued and the write-off was non-capital in nature. The analysis turned on commercial expediency: the subsidiary was set up to further the assessee's business interests and sourced goods exclusively from the assessee, so the advances formed part of the assessee's business operations. The recipient's treatment of the funds as capital or quasi-equity did not determine deductibility in the assessee's hands. On that reasoning, the disallowance was unsustainable and the write-off was allowable. Case-Laws Income Tax Fri, 24 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=341086