Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Delayed trade receivables from an associated enterprise that remain unpaid beyond the agreed credit period are treated as a separate financing transaction and require independent arm's length benchmarking. Only the delay exceeding the actual arm's length credit period should attract interest, calculated in the receivable currency with a justified spread; LIBOR plus 200 basis points is prescribed for foreign-currency receivables. For ITES comparable selection, verification is required of the service-income and 25% related-party transaction filters. The turnover filter excludes companies with turnover above ten times or below one-tenth of the tested party's turnover.
Delayed trade receivables from an associated enterprise that remain unpaid beyond the agreed credit period are treated as a separate financing transaction and require independent arm's length benchmarking. Only the delay exceeding the actual arm's length credit period should attract interest, calculated in the receivable currency with a justified spread; LIBOR plus 200 basis points is prescribed for foreign-currency receivables. For ITES comparable selection, verification is required of the service-income and 25% related-party transaction filters. The turnover filter excludes companies with turnover above ten times or below one-tenth of the tested party's turnover.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
