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Transfer-pricing adjustments on interest-free loans to overseas...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallowed.
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Transfer-pricing adjustments on interest-free loans to overseas associated enterprises were deleted because LIBOR-based benchmarking had been accepted on similar facts; continuing corporate guarantees were treated as international transactions, with commission restricted to 0.35%. Premature settlement of deferred sales-tax liability at net present value produced a capital receipt, not taxable remission, and no book-profit adjustment survived. Business losses on unrecovered premises deposits, capital-loan waiver and overseas subsidiary loans and investments were allowed on the stated facts, while property-advance write-offs were disallowed for lack of business nexus. No further exempt-income disallowance or book-profit addition was warranted. Captive-power pricing could use the electricity-board purchase price as a comparable. Uncross-examined third-party statements could not support cargo-expense disallowance, and ESOP claims could be admitted on appeal subject to verification.
Transfer-pricing adjustments on interest-free loans to overseas associated enterprises were deleted because LIBOR-based benchmarking had been accepted on similar facts; continuing corporate guarantees were treated as international transactions, with commission restricted to 0.35%. Premature settlement of deferred sales-tax liability at net present value produced a capital receipt, not taxable remission, and no book-profit adjustment survived. Business losses on unrecovered premises deposits, capital-loan waiver and overseas subsidiary loans and investments were allowed on the stated facts, while property-advance write-offs were disallowed for lack of business nexus. No further exempt-income disallowance or book-profit addition was warranted. Captive-power pricing could use the electricity-board purchase price as a comparable. Uncross-examined third-party statements could not support cargo-expense disallowance, and ESOP claims could be admitted on appeal subject to verification.
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