GST Reversal Provision Permissible as Business Expenditure in Correct Financial Year Upon Assessing Officer Verification Issue Whether a provision made for GST reversal under rules 42 and 43 of the CGST Rules, 2017 is allowable as business expenditure under section 37(1), and in which specific assessment year (AY 2022-23 vs. AY 2023-24) the deduction should… Read More »
Brought-forward R&D losses forgone under section 35(2AB) are independently re-examinable under sections 35(1) or 37(1) for section 115BAA set-off. Issue Whether carried-forward R&D expenditure loss, originally claimed under section 35(2AB) with weighted deduction but later forgone to actual expenditure, can be re-examined and allowed under sections 35(1)(i), 35(1)(iv), or 37(1) for set-off under the concessional… Read More »
Transfer pricing adjustments on bank guarantees and loan support services are legally unsustainable without proper FAR analysis. Issue Whether transfer pricing adjustments made on counter/back-to-back guarantees (without establishing FAR comparability or data confrontation) and the arbitrary attribution of 50 percent net interest/fee income for loan support services (without a prescribed method or comparables) are sustainable?… Read More »