Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Page of 4830
Press 'Enter' after typing page number.
141 to 160 of 96587 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
