Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Page of 4807
Press 'Enter' after typing page number.
2401 to 2420 of 96136 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The Appellate Tribunal addressed two key issues. Firstly, regarding speculative transactions u/s 43(5), it was determined that the transactions of purchasing and selling canola oil on high seas did not qualify as speculative as actual delivery of goods occurred to the ultimate buyer. Citing precedents, the Tribunal emphasized that physical delivery to the ultimate purchaser exempts transactions from being deemed speculative. Secondly, concerning the addition as interest income u/s 36(1)(iii), the Tribunal ruled in favor of the assessee. It was noted that the audited balance sheet substantiated the availability of interest-free funds, which were deemed adequate to cover the interest-free advances made. Following a Supreme Court decision, the addition made by the AO was deleted.
The Appellate Tribunal addressed two key issues. Firstly, regarding speculative transactions u/s 43(5), it was determined that the transactions of purchasing and selling canola oil on high seas did not qualify as speculative as actual delivery of goods occurred to the ultimate buyer. Citing precedents, the Tribunal emphasized that physical delivery to the ultimate purchaser exempts transactions from being deemed speculative. Secondly, concerning the addition as interest income u/s 36(1)(iii), the Tribunal ruled in favor of the assessee. It was noted that the audited balance sheet substantiated the availability of interest-free funds, which were deemed adequate to cover the interest-free advances made. Following a Supreme Court decision, the addition made by the AO was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4807
Join Channel
TaxTMI 
