Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
TP Adjustment - Eligible International Transaction - safe harbor rules - The court examined the eligibility of international transactions under Rule 10TC of the Income Tax Rules and concluded that certain transactions, including interest on outstanding receivables, did not fall under the scope of Safe Harbour Rules. Therefore, the court rejected the appellant's argument that the Safe Harbour mark-up of 25% precluded any further ALP adjustment. - Regarding the transfer pricing adjustment for interest on outstanding receivables, the ITAT in line with Tribunal decisions, revised the interest rate calculation from LIBOR + 400 basis points to LIBOR + 200 basis points. This adjustment was deemed equitable and balanced for both parties.
TP Adjustment - Eligible International Transaction - safe harbor rules - The court examined the eligibility of international transactions under Rule 10TC of the Income Tax Rules and concluded that certain transactions, including interest on outstanding receivables, did not fall under the scope of Safe Harbour Rules. Therefore, the court rejected the appellant's argument that the Safe Harbour mark-up of 25% precluded any further ALP adjustment. - Regarding the transfer pricing adjustment for interest on outstanding receivables, the ITAT in line with Tribunal decisions, revised the interest rate calculation from LIBOR + 400 basis points to LIBOR + 200 basis points. This adjustment was deemed equitable and balanced for both parties.
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