Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
Corporate guarantee furnished to an associated enterprise for credit facilities was treated as an international transaction because the statutory explanation to section 92B covers capital financing, including guarantees, and the guarantee had a direct bearing on the enterprise's financial position; the transfer pricing challenge on that point failed. For arm's length commission, the Tribunal held that the guarantee exposure changed during the year as the underlying loan was repaid, so the risk assumed could not be measured only by the year-end balance. It sustained computation of commission at 0.50% on the average of opening and closing outstanding exposure, and dismissed the appeals.
Corporate guarantee furnished to an associated enterprise for credit facilities was treated as an international transaction because the statutory explanation to section 92B covers capital financing, including guarantees, and the guarantee had a direct bearing on the enterprise's financial position; the transfer pricing challenge on that point failed. For arm's length commission, the Tribunal held that the guarantee exposure changed during the year as the underlying loan was repaid, so the risk assumed could not be measured only by the year-end balance. It sustained computation of commission at 0.50% on the average of opening and closing outstanding exposure, and dismissed the appeals.
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