Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
The ITAT addressed two main issues: 1. TP Adjustment for...
ITAT says corporate guarantee to AE is not a financial service by assessee. No profit shifting or burden. Interest adjustment on AEs' receivables unjustified.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
The ITAT addressed two main issues: 1. TP Adjustment for corporate guarantee to AE: As the assessee did not provide guarantees to unrelated parties, it was not a financial service. The low profit rate of AE and adequate security indicated no profit shifting. Citing PCIT Vs Redington, the adjustment was deleted as it did not affect the assessee's finances. 2. Addition of interest on overdue receivables from AEs: TPO applied a 60-day credit policy, contrary to the assessee's 180-day policy in line with RBI guidelines. Following GSS Infotech Ltd, interest was not charged to AEs or non-AEs, so adding notional interest was unjustified. Referring to CIT Vs Indo American Jewellery Ltd, the interest adjustment was deleted.
The ITAT addressed two main issues: 1. TP Adjustment for corporate guarantee to AE: As the assessee did not provide guarantees to unrelated parties, it was not a financial service. The low profit rate of AE and adequate security indicated no profit shifting. Citing PCIT Vs Redington, the adjustment was deleted as it did not affect the assessee's finances. 2. Addition of interest on overdue receivables from AEs: TPO applied a 60-day credit policy, contrary to the assessee's 180-day policy in line with RBI guidelines. Following GSS Infotech Ltd, interest was not charged to AEs or non-AEs, so adding notional interest was unjustified. Referring to CIT Vs Indo American Jewellery Ltd, the interest adjustment was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
