Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Transfer Pricing Adjustment on Delayed Sales Proceeds - Normally there would be a difference between the lending rate and borrowing rate in each country. Some authors and writers suggest that the average or mid-point between the two should be taken. However, others like Klaus Vogel have suggested that economic purpose and substance of the debt-claim or debt for which granting of credit calls for the lending rate would be determinative. - The ITAT observed that, we do not deem it necessary to enter into this controversy and express our view as regards the same. - The ITAT held that the interest rate on delayed sales proceeds should be based on the currency in which the loan is to be repaid, favoring the application of LIBOR over the Indian Prime Lending Rate (PLR).
Transfer Pricing Adjustment on Delayed Sales Proceeds - Normally there would be a difference between the lending rate and borrowing rate in each country. Some authors and writers suggest that the average or mid-point between the two should be taken. However, others like Klaus Vogel have suggested that economic purpose and substance of the debt-claim or debt for which granting of credit calls for the lending rate would be determinative. - The ITAT observed that, we do not deem it necessary to enter into this controversy and express our view as regards the same. - The ITAT held that the interest rate on delayed sales proceeds should be based on the currency in which the loan is to be repaid, favoring the application of LIBOR over the Indian Prime Lending Rate (PLR).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
