Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Where not only the bonds were raised outside India, but the interest payments were also made to non-residents outside India from a bank account held by the assessee outside India, no part of the transaction relating to payment of interest has taken place in India. Therefore, it cannot be said that the interest payment made to non-residents has accrued or arisen in India u/s 9.
Where not only the bonds were raised outside India, but the interest payments were also made to non-residents outside India from a bank account held by the assessee outside India, no part of the transaction relating to payment of interest has taken place in India. Therefore, it cannot be said that the interest payment made to non-residents has accrued or arisen in India u/s 9.
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