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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
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ITAT dismissed the Revenue's appeal and upheld that the assessee was not liable to deduct tax at source under section 194A. The Tribunal held that payments made to the transferor entities for acquisition of ICDs, NCDs and term loans, including accrued interest up to the date of transfer, constituted lump-sum purchase consideration for capital assets and did not amount to "interest" payable by the assessee. Consequently, no borrower-lender relationship arose between the parties and the assessee was not in default within the meaning of sections 201(1)/201(1A). The appellate authority's finding that no obligation to deduct TDS under section 194A existed was affirmed.
ITAT dismissed the Revenue's appeal and upheld that the assessee was not liable to deduct tax at source under section 194A. The Tribunal held that payments made to the transferor entities for acquisition of ICDs, NCDs and term loans, including accrued interest up to the date of transfer, constituted lump-sum purchase consideration for capital assets and did not amount to "interest" payable by the assessee. Consequently, no borrower-lender relationship arose between the parties and the assessee was not in default within the meaning of sections 201(1)/201(1A). The appellate authority's finding that no obligation to deduct TDS under section 194A existed was affirmed.
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