Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
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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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