Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Arm's length interest on Indian rupee-denominated NCDs issued to an associated enterprise requires benchmarking against the domestic lending environment and PLR. EBLR-based rates cannot be adopted merely because the PLR regime was replaced for specified bank lending; for fixed-rate NCDs, reliable comparability must be established across tenure, repayment terms, security, interest structure, credit profile, subordination and contractual terms. A credit-risk premium does not cure inadequate comparability analysis. Applying SBI BPLR/PLR to recompute arm's length interest was sustained, and the Revenue's appeals were dismissed for both assessment years.
Arm's length interest on Indian rupee-denominated NCDs issued to an associated enterprise requires benchmarking against the domestic lending environment and PLR. EBLR-based rates cannot be adopted merely because the PLR regime was replaced for specified bank lending; for fixed-rate NCDs, reliable comparability must be established across tenure, repayment terms, security, interest structure, credit profile, subordination and contractual terms. A credit-risk premium does not cure inadequate comparability analysis. Applying SBI BPLR/PLR to recompute arm's length interest was sustained, and the Revenue's appeals were dismissed for both assessment years.
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TaxTMI 
TaxTMI 
