Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
TP Adjustment - Interest on External Commercial Borrowing (ECB) - The Tribunal found that the term of the ECB loan was indeed five years, not four years as asserted by the Revenue authorities. Considering past acceptance of similar interest rates by the TPO, the Tribunal ruled in favor of the assessee, allowing the interest payment on ECBs at the claimed rate.
TP Adjustment - Interest on External Commercial Borrowing (ECB) - The Tribunal found that the term of the ECB loan was indeed five years, not four years as asserted by the Revenue authorities. Considering past acceptance of similar interest rates by the TPO, the Tribunal ruled in favor of the assessee, allowing the interest payment on ECBs at the claimed rate.
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