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Transfer-pricing treatment limited corporate-guarantee commission to 0.5% and associated-enterprise loan interest to 9% by applying earlier-year benchmarks. Withholding-tax disallowances were removed for overseas legal fees and export commission paid to non-resident agents for services outside India, whereas non-withholding on payments to an offshore branch of an Indian bank was sustained for professional or technical services. Annual GDR listing and maintenance fees, foreign travel expenditure, and the section 80-IA captive-power deduction were allowed. Carbon-credit sale proceeds were treated as capital receipts. Mining-development expenditure capitalised in the accounts was not deductible as revenue expenditure, but qualified for applicable depreciation.
Transfer-pricing treatment limited corporate-guarantee commission to 0.5% and associated-enterprise loan interest to 9% by applying earlier-year benchmarks. Withholding-tax disallowances were removed for overseas legal fees and export commission paid to non-resident agents for services outside India, whereas non-withholding on payments to an offshore branch of an Indian bank was sustained for professional or technical services. Annual GDR listing and maintenance fees, foreign travel expenditure, and the section 80-IA captive-power deduction were allowed. Carbon-credit sale proceeds were treated as capital receipts. Mining-development expenditure capitalised in the accounts was not deductible as revenue expenditure, but qualified for applicable depreciation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
