Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
The ITAT Hyderabad upheld the Corporate Guarantee Commission at 0.53% for guarantees to foreign AEs, rejecting the AO's 1.8% rate. The tribunal determined the pro rata guarantee at 30.50% of a $10 million loan balance. The CIT(A) classified corporate guarantees as international transactions and set the commission at 0.53%. Interest on trade receivables was benchmarked at 6% SBI rate. The tribunal remanded R&D, Head Office, and Marketing expenses issues back to the AO/TPO for fresh assessment, citing a violation of natural justice. The tribunal directed the assessee to provide segmental accounts for accurate benchmarking. The tribunal excluded certain comparables based on RPT filter agreement.
The ITAT Hyderabad upheld the Corporate Guarantee Commission at 0.53% for guarantees to foreign AEs, rejecting the AO's 1.8% rate. The tribunal determined the pro rata guarantee at 30.50% of a $10 million loan balance. The CIT(A) classified corporate guarantees as international transactions and set the commission at 0.53%. Interest on trade receivables was benchmarked at 6% SBI rate. The tribunal remanded R&D, Head Office, and Marketing expenses issues back to the AO/TPO for fresh assessment, citing a violation of natural justice. The tribunal directed the assessee to provide segmental accounts for accurate benchmarking. The tribunal excluded certain comparables based on RPT filter agreement.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
