Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
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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