Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displa...
Final benami adjudication bars contradictory tax-evasion prosecution where settlement findings confirm full disclosure and cooperation without conceal...
Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
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 4908 
