Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
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.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
