Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
The ITAT Hyderabad addressed a Transfer Pricing (TP) Adjustment issue regarding interest on outstanding receivables, determining if it constitutes an international transaction. Referring to the amendment to Section 92B of the Act by the Finance Act, 2012, the Tribunal held that interest on outstanding receivables is indeed an international transaction requiring separate benchmarking. The Tribunal noted that the DRP directed the AO to use the SBI short-term deposit interest rate as the Arm's Length Price (ALP) interest rate and adjust income based on a credit period of thirty days or as per the agreement/invoice. The Tribunal directed the AO/TPO to compute the interest rate on similar foreign currency receivables/advances as LIBOR+200 points, applying the appropriate credit period. The Tribunal allowed the grounds in part, emphasizing the need for accurate computation and adherence to the specified credit period.
The ITAT Hyderabad addressed a Transfer Pricing (TP) Adjustment issue regarding interest on outstanding receivables, determining if it constitutes an international transaction. Referring to the amendment to Section 92B of the Act by the Finance Act, 2012, the Tribunal held that interest on outstanding receivables is indeed an international transaction requiring separate benchmarking. The Tribunal noted that the DRP directed the AO to use the SBI short-term deposit interest rate as the Arm's Length Price (ALP) interest rate and adjust income based on a credit period of thirty days or as per the agreement/invoice. The Tribunal directed the AO/TPO to compute the interest rate on similar foreign currency receivables/advances as LIBOR+200 points, applying the appropriate credit period. The Tribunal allowed the grounds in part, emphasizing the need for accurate computation and adherence to the specified credit period.
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