https://www.taxtmi.com/caselaws?id=463358 HC set aside the Tribunal's order and remanded the matter for fresh consideration, holding that the Tribunal erred in treating foreign exchange loss as capital by improperly lifting the corporate veil. The court found the loan was taken to fund a Mauritius subsidiary to acquire a South African business for commercial expediency and cost reduction, so deductibility under section 37 requires assessment from a prudent businessman's viewpoint. The HC held veil lifting was inapplicable absent fraud or illegality and directed reconsideration mindful of commercial expediency and relevant DTAA principles. en-us Wed, 04 Aug 2021 00:00:00 +0530 Wed, 27 Aug 2025 19:01:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463358 HC set aside the Tribunal's order and remanded the matter for fresh consideration, holding that the Tribunal erred in treating foreign exchange loss as capital by improperly lifting the corporate veil. The court found the loan was taken to fund a Mauritius subsidiary to acquire a South African business for commercial expediency and cost reduction, so deductibility under section 37 requires assessment from a prudent businessman's viewpoint. The HC held veil lifting was inapplicable absent fraud or illegality and directed reconsideration mindful of commercial expediency and relevant DTAA principles. Case-Laws Income Tax Wed, 04 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463358