Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
