Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Addition u/s 40A(2) - assessee has paid interest to certain related parties and treated interest rate @ 15% reasonable and disallowed excess rate paid to related parties u/s.40A(2) - different banks/NBFC’s are having different interest rates for business loan if any one require loan in emergency from local money lenders then in that case one has to pay interest rate between 48% to 60%. So in our considered opinion in this case difference of interest which was received by the assessee or paid by it is just 1.25% per annum so same cannot be termed as unreasonable. - AT
Addition u/s 40A(2) - assessee has paid interest to certain related parties and treated interest rate @ 15% reasonable and disallowed excess rate paid to related parties u/s.40A(2) - different banks/NBFC’s are having different interest rates for business loan if any one require loan in emergency from local money lenders then in that case one has to pay interest rate between 48% to 60%. So in our considered opinion in this case difference of interest which was received by the assessee or paid by it is just 1.25% per annum so same cannot be termed as unreasonable. - AT
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