Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The ITAT Chennai addressed several issues. Firstly, regarding TDS u/s 195/192, it held that payments made to overseas group entities for relocation expenses of secondment employees were not subject to TDS as they were reimbursement of internal business costs, not taxable income. The matter was remitted to the AO for verification. Secondly, non-credit of DDT paid u/s 115O was remitted for verification of the amount paid. Thirdly, DDT liability u/s 115-O for dividends paid to a UK entity was to be decided by lower authorities. Lastly, lease rental payments were allowed as deductible expenses, with depreciation on assets taken on finance lease being part of the disallowance under section 32. The confusion created by the AO was clarified, and the Revenue's appeal on this issue was dismissed.
The ITAT Chennai addressed several issues. Firstly, regarding TDS u/s 195/192, it held that payments made to overseas group entities for relocation expenses of secondment employees were not subject to TDS as they were reimbursement of internal business costs, not taxable income. The matter was remitted to the AO for verification. Secondly, non-credit of DDT paid u/s 115O was remitted for verification of the amount paid. Thirdly, DDT liability u/s 115-O for dividends paid to a UK entity was to be decided by lower authorities. Lastly, lease rental payments were allowed as deductible expenses, with depreciation on assets taken on finance lease being part of the disallowance under section 32. The confusion created by the AO was clarified, and the Revenue's appeal on this issue was dismissed.
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