Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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TP Adjustment - assessee has issued the corporate guarantee on behalf of AE’s - interest saved approach - The ITAT decided in favor of the assessee, directing the AO to restrict the addition by splitting the interest benefit on a 50:50 basis between the guarantor and the borrower. It was noted that earlier years' tribunals had accepted a splitting of the interest savings as a reasonable approach. - With regard to Royalty, the ITAT allowed the assessee's grounds concerning TP adjustments related to the charge of brand royalty, following earlier tribunal decisions that set specific rates for such royalties.
TP Adjustment - assessee has issued the corporate guarantee on behalf of AE’s - interest saved approach - The ITAT decided in favor of the assessee, directing the AO to restrict the addition by splitting the interest benefit on a 50:50 basis between the guarantor and the borrower. It was noted that earlier years' tribunals had accepted a splitting of the interest savings as a reasonable approach. - With regard to Royalty, the ITAT allowed the assessee's grounds concerning TP adjustments related to the charge of brand royalty, following earlier tribunal decisions that set specific rates for such royalties.
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