Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
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Foreign-currency loans repayable in US dollars were benchmarked using LIBOR plus 300 basis points rather than a domestic lending rate, and that transfer-pricing direction was sustained. Under TNMM, comparables must satisfy functional and product comparability; sectorally distinct engineering services and aluminium-capacitor manufacturing entities were excluded. No arm's-length interest adjustment applied to delayed associated-enterprise receivables where no interest was charged to either associated or non-associated enterprises and transaction pricing already reflected margins. Expenditure relating to investments could not be disallowed where no exempt dividend income was received or receivable during the year. The assessee's and Revenue's appeals were dismissed.
Foreign-currency loans repayable in US dollars were benchmarked using LIBOR plus 300 basis points rather than a domestic lending rate, and that transfer-pricing direction was sustained. Under TNMM, comparables must satisfy functional and product comparability; sectorally distinct engineering services and aluminium-capacitor manufacturing entities were excluded. No arm's-length interest adjustment applied to delayed associated-enterprise receivables where no interest was charged to either associated or non-associated enterprises and transaction pricing already reflected margins. Expenditure relating to investments could not be disallowed where no exempt dividend income was received or receivable during the year. The assessee's and Revenue's appeals were dismissed.
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