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 directed exclusion of three companies (Wipro Limited, Infosys Ltd., and Tata Elexi Limited) as comparables for transfer pricing adjustments, relying on precedents from Delhi HC in Agnity India Technologies and Avaya India cases. Regarding interest on outstanding receivables from AEs, the Tribunal remanded the issue to AO/TPO to examine industry practices and any mutual payment agreements. The ITAT held that if receivables are within industry average holding periods or contractual terms, adjustment may not be warranted. The Tribunal found LIBOR plus 425 basis points excessive for computing interest, suggesting that a rate based solely on LIBOR would be more appropriate. The appeal was allowed for statistical purposes.
The ITAT directed exclusion of three companies (Wipro Limited, Infosys Ltd., and Tata Elexi Limited) as comparables for transfer pricing adjustments, relying on precedents from Delhi HC in Agnity India Technologies and Avaya India cases. Regarding interest on outstanding receivables from AEs, the Tribunal remanded the issue to AO/TPO to examine industry practices and any mutual payment agreements. The ITAT held that if receivables are within industry average holding periods or contractual terms, adjustment may not be warranted. The Tribunal found LIBOR plus 425 basis points excessive for computing interest, suggesting that a rate based solely on LIBOR would be more appropriate. The appeal was allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
