Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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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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