Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
ITAT Decision: Infrastructure Project Tax Deduction Dispute The ITAT partially allowed the revenue's appeal, addressing multiple taxation issues. The Tribunal upheld deductions for interest income from fixed deposits directly linked to infrastructure project financing, rejecting revenue's challenge. The Tribunal recognized the business expediency of interest-free advances to a subsidiary for project development, dismissing proportionate interest expense disallowance. Concession fee was deemed allowable on accrual basis, consistent with prior rulings. However, guarantee commission income was disallowed under section 80IA, being considered unrelated to core airport infrastructure operations. The Tribunal directed the Assessing Officer to verify specific quantum of expenditures and make appropriate adjustments, essentially providing a nuanced resolution balancing taxpayer's claims and statutory interpretations.
ITAT Decision: Infrastructure Project Tax Deduction Dispute The ITAT partially allowed the revenue's appeal, addressing multiple taxation issues. The Tribunal upheld deductions for interest income from fixed deposits directly linked to infrastructure project financing, rejecting revenue's challenge. The Tribunal recognized the business expediency of interest-free advances to a subsidiary for project development, dismissing proportionate interest expense disallowance. Concession fee was deemed allowable on accrual basis, consistent with prior rulings. However, guarantee commission income was disallowed under section 80IA, being considered unrelated to core airport infrastructure operations. The Tribunal directed the Assessing Officer to verify specific quantum of expenditures and make appropriate adjustments, essentially providing a nuanced resolution balancing taxpayer's claims and statutory interpretations.
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