Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
TP adjustment - Since the funds have been borrowed in USD and also advanced in USD, the currency and exchange risks are minimised and the only risk to be considered is the lending risk for determining the markup. - No infirmity in the impugned order in treating 7.375% plus markup of 1% as the arm’s length rate of interest in respect of loan advanced by the assessee to its AE. - AT
TP adjustment - Since the funds have been borrowed in USD and also advanced in USD, the currency and exchange risks are minimised and the only risk to be considered is the lending risk for determining the markup. - No infirmity in the impugned order in treating 7.375% plus markup of 1% as the arm’s length rate of interest in respect of loan advanced by the assessee to its AE. - AT
Note: It is a system-generated summary and is for quick reference only.
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