SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Page of 4878
Press 'Enter' after typing page number.
121 to 140 of 97553 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Internal comparable pricing of interest on compulsorily...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for transfer-pricing purposes.
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
Internal comparable pricing of interest on compulsorily convertible debentures applied where subscriptions under the same agreement carried identical material terms and no relevant change was established. The comparable supported acceptance of the 15% interest rate as arm's length and deletion of the transfer-pricing adjustment based on treating the debentures as equity. Interest disallowance for payments to a foreign associated enterprise required factual verification of the correct associated-enterprise interest. Set-off of brought-forward business losses likewise required verification of quantum, availability, and appellate effect. A challenge solely to initiation of penalty proceedings was premature.
Internal comparable pricing of interest on compulsorily convertible debentures applied where subscriptions under the same agreement carried identical material terms and no relevant change was established. The comparable supported acceptance of the 15% interest rate as arm's length and deletion of the transfer-pricing adjustment based on treating the debentures as equity. Interest disallowance for payments to a foreign associated enterprise required factual verification of the correct associated-enterprise interest. Set-off of brought-forward business losses likewise required verification of quantum, availability, and appellate effect. A challenge solely to initiation of penalty proceedings was premature.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
