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Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
The TPO benchmarked the ECB transaction using CUP method and SBI base rate as CUP, but failed to consider factors like credit rating, future revenue projections, and terms of loan agreement. The assessee didn't carry out proper TP analysis. The interest rate determination suffers from defects. SBI base rate alone isn't appropriate as banks don't lend at base rate to corporates. The DRP correctly held arm's length interest as SBI base rate plus 25 bps on simple interest basis, considering future growth projections and minimal risk. The ACIT had jurisdiction u/s 144B(8) to pass final assessment order after case transfer with CBDT approval. The final assessment order is valid.
The TPO benchmarked the ECB transaction using CUP method and SBI base rate as CUP, but failed to consider factors like credit rating, future revenue projections, and terms of loan agreement. The assessee didn't carry out proper TP analysis. The interest rate determination suffers from defects. SBI base rate alone isn't appropriate as banks don't lend at base rate to corporates. The DRP correctly held arm's length interest as SBI base rate plus 25 bps on simple interest basis, considering future growth projections and minimal risk. The ACIT had jurisdiction u/s 144B(8) to pass final assessment order after case transfer with CBDT approval. The final assessment order is valid.
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TaxTMI 
TaxTMI 
