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 - 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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