Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
Fully and compulsorily convertible debentures retain debt character until conversion, so pre-conversion interest cannot be benchmarked at nil by recharacterising them as equity. The transfer pricing authorities had not carried out an independent benchmarking exercise, so the arm's length price of the interest was remitted for fresh determination. For receivables from associated enterprises, notional interest was upheld in principle, but the adjustment had to be recomputed after allowing a 90-day credit period.
Fully and compulsorily convertible debentures retain debt character until conversion, so pre-conversion interest cannot be benchmarked at nil by recharacterising them as equity. The transfer pricing authorities had not carried out an independent benchmarking exercise, so the arm's length price of the interest was remitted for fresh determination. For receivables from associated enterprises, notional interest was upheld in principle, but the adjustment had to be recomputed after allowing a 90-day credit period.
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