Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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Transfer-pricing treatment of corporate guarantees to wholly owned associated enterprises is discussed as requiring an arm's length commission of 0.5%, rather than a bank-guarantee rate of 1.90%. For outstanding foreign-currency receivables from associated enterprises, the relevant benchmark is the market rate for the transaction currency, identified as LIBOR plus 200 basis points rather than domestic lending or deposit rates. A normal interest-free credit period of 60 days is to be allowed before computing interest. The resulting adjustments are confined to the guarantee commission and recomputation of receivables interest on those parameters.
Transfer-pricing treatment of corporate guarantees to wholly owned associated enterprises is discussed as requiring an arm's length commission of 0.5%, rather than a bank-guarantee rate of 1.90%. For outstanding foreign-currency receivables from associated enterprises, the relevant benchmark is the market rate for the transaction currency, identified as LIBOR plus 200 basis points rather than domestic lending or deposit rates. A normal interest-free credit period of 60 days is to be allowed before computing interest. The resulting adjustments are confined to the guarantee commission and recomputation of receivables interest on those parameters.
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