Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
The ITAT held that the assessment against the company was valid despite the merger, as the amalgamated and amalgamating companies continued to exist for concluding litigations and exhausting demands. Regarding transfer pricing adjustment, outstanding receivables with associated enterprises cannot be benchmarked separately as they arise in the regular course of business. The interest rate should be LIBOR+200 basis points, following precedents. For determining arm's length price, both trade receivables and payables should be considered for notional interest calculation.
The ITAT held that the assessment against the company was valid despite the merger, as the amalgamated and amalgamating companies continued to exist for concluding litigations and exhausting demands. Regarding transfer pricing adjustment, outstanding receivables with associated enterprises cannot be benchmarked separately as they arise in the regular course of business. The interest rate should be LIBOR+200 basis points, following precedents. For determining arm's length price, both trade receivables and payables should be considered for notional interest calculation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
