Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Disallowance of interest u/s 40A - The unsecured borrowings by a commercial organisation like the assessee, on these facts, @ 16% interest seems to be reasonable. The benchmark @ 14% adopted by the ld. CIT(A), by taking fixed deposit interest rates of companies like MGF Limited and Rama Vision Ltd., cannot be applied in a rigid way. - AT
Disallowance of interest u/s 40A - The unsecured borrowings by a commercial organisation like the assessee, on these facts, @ 16% interest seems to be reasonable. The benchmark @ 14% adopted by the ld. CIT(A), by taking fixed deposit interest rates of companies like MGF Limited and Rama Vision Ltd., cannot be applied in a rigid way. - AT
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