Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displa...
Final benami adjudication bars contradictory tax-evasion prosecution where settlement findings confirm full disclosure and cooperation without conceal...
Corporate guarantees issued for an associated enterprise's borrowing fall within capital financing and constitute international transactions where they enhance the enterprise's creditworthiness and expose the guarantor to risk. Arm's-length pricing is therefore required. Where no pricing method or transfer-pricing study computation is provided, an annual 0.5% guarantee fee determined using the uncontrolled-price standard under Rule 10AB is sustained. Guarantee fee is not profit derived from SEZ development and is ineligible for the SEZ deduction. Tax deducted at source credit reflected in Form 26AS requires verification before eligible credit is granted.
Corporate guarantees issued for an associated enterprise's borrowing fall within capital financing and constitute international transactions where they enhance the enterprise's creditworthiness and expose the guarantor to risk. Arm's-length pricing is therefore required. Where no pricing method or transfer-pricing study computation is provided, an annual 0.5% guarantee fee determined using the uncontrolled-price standard under Rule 10AB is sustained. Guarantee fee is not profit derived from SEZ development and is ineligible for the SEZ deduction. Tax deducted at source credit reflected in Form 26AS requires verification before eligible credit is granted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
