Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The ITAT held that an outstanding balance taken over under a Business Transfer Agreement in a slump sale could not be treated as an interest-free advance to a group company for making a deemed interest addition. It accepted that the amount was not an actual loan from borrowed funds but part of a commercially expedient business arrangement, and also relied on the Revenue's consistent acceptance of the same position in later years. The Tribunal further found that a larger notional disallowance was untenable where the actual interest debited in the year was minimal. The impugned addition was deleted and income was directed to be recomputed accordingly.
The ITAT held that an outstanding balance taken over under a Business Transfer Agreement in a slump sale could not be treated as an interest-free advance to a group company for making a deemed interest addition. It accepted that the amount was not an actual loan from borrowed funds but part of a commercially expedient business arrangement, and also relied on the Revenue's consistent acceptance of the same position in later years. The Tribunal further found that a larger notional disallowance was untenable where the actual interest debited in the year was minimal. The impugned addition was deleted and income was directed to be recomputed accordingly.
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