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Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated effective borrowing cost including guarantee fee was lower than bank's quoted interest rate, justifying economic rationale. Tax authorities failed to present compelling evidence against guarantee fee. Benefits of lower interest rates and favorable operating margins substantiated arm's length nature. Tribunal had deleted similar addition previously, upheld by High Court considering consistency in operating margin, benefit of lower borrowing costs compared to bank rates justifying guarantee fee. Present case mirrored facts and circumstances, necessitating consistency in judicial decisions for legal certainty and fairness. TP adjustment made by tax authorities was unjustified, addition on account of guarantee fee payment to associated enterprise was deleted.
Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated effective borrowing cost including guarantee fee was lower than bank's quoted interest rate, justifying economic rationale. Tax authorities failed to present compelling evidence against guarantee fee. Benefits of lower interest rates and favorable operating margins substantiated arm's length nature. Tribunal had deleted similar addition previously, upheld by High Court considering consistency in operating margin, benefit of lower borrowing costs compared to bank rates justifying guarantee fee. Present case mirrored facts and circumstances, necessitating consistency in judicial decisions for legal certainty and fairness. TP adjustment made by tax authorities was unjustified, addition on account of guarantee fee payment to associated enterprise was deleted.
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TaxTMI 
TaxTMI 
of 4884 
