Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and interest...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from exempt-income calculations.
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 treatment of corporate guarantees and interest on convertible loans followed consistent prior-year treatment where no factual difference was shown. Payments to non-residents, product, trademark and patent registration expenses, in-house research and development deductions, vehicle depreciation, and partner remuneration were also addressed through established prior-year positions. Exempt-income expenditure disallowance is computed only by reference to investments yielding exempt income; foreign investments generating taxable dividends require exclusion, subject to verification. Foreign-currency royalty receipts already recorded and offered to tax cannot be treated as undisclosed income without supporting material. Employee contributions already disallowed by the taxpayer cannot be disallowed again.
Transfer-pricing treatment of corporate guarantees and interest on convertible loans followed consistent prior-year treatment where no factual difference was shown. Payments to non-residents, product, trademark and patent registration expenses, in-house research and development deductions, vehicle depreciation, and partner remuneration were also addressed through established prior-year positions. Exempt-income expenditure disallowance is computed only by reference to investments yielding exempt income; foreign investments generating taxable dividends require exclusion, subject to verification. Foreign-currency royalty receipts already recorded and offered to tax cannot be treated as undisclosed income without supporting material. Employee contributions already disallowed by the taxpayer cannot be disallowed again.
Note: It is a system-generated summary and is for quick reference only.