Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
Subscription to and redemption of non-cumulative redeemable preference shares could not be re-characterised as an unsecured loan for transfer pricing purposes in the absence of material showing a sham or concealment of the real transaction; with only an opening balance and minor redemption, the notional interest adjustment was deleted. On advances to subsidiaries, the assessee's substantial own funds and interest-free funds exceeded the advances, so the presumption applied that the advances came from own funds rather than borrowed funds, and the interest disallowance was deleted. The Revenue's appeal was dismissed.
Subscription to and redemption of non-cumulative redeemable preference shares could not be re-characterised as an unsecured loan for transfer pricing purposes in the absence of material showing a sham or concealment of the real transaction; with only an opening balance and minor redemption, the notional interest adjustment was deleted. On advances to subsidiaries, the assessee's substantial own funds and interest-free funds exceeded the advances, so the presumption applied that the advances came from own funds rather than borrowed funds, and the interest disallowance was deleted. The Revenue's appeal was dismissed.
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