Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Disallowance of expenditure u/s 14A read with rule 8D - proportionate disallowance of interest - common pool of funds - if we apply the ratio laid down in the various decisions as discussed to the facts of the present case, the inescapable conclusion would be, as per the balance-sheet the assessee had sufficient interest free fund available with it to take care of the investment. That being the factual position, presumption would be, the investments have been made out of the interest free funds available with the assessee. Hence, no disallowance under rule 8D(2)(ii) can be made. - AT
Disallowance of expenditure u/s 14A read with rule 8D - proportionate disallowance of interest - common pool of funds - if we apply the ratio laid down in the various decisions as discussed to the facts of the present case, the inescapable conclusion would be, as per the balance-sheet the assessee had sufficient interest free fund available with it to take care of the investment. That being the factual position, presumption would be, the investments have been made out of the interest free funds available with the assessee. Hence, no disallowance under rule 8D(2)(ii) can be made. - AT
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