Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Page of 4796
Press 'Enter' after typing page number.
681 to 700 of 95916 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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 4796
Join Channel
TaxTMI 
