Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Transfer pricing adjustment on interest paid on compulsorily convertible debentures issued to a non-resident associated enterprise turned on the appropriate benchmark for arm's length interest where the CCDs were denominated in Indian currency. Applying the governing precedent, it was held that such INR-denominated CCD interest must be benchmarked using domestic Prime Lending Rate (PLR) rather than foreign currency benchmarks. Consequently, the adjustment/addition made by the tax authorities on account of ALP computation of interest on the CCDs was held unjustified and was deleted, and the appeal was allowed. - ITAT
Transfer pricing adjustment on interest paid on compulsorily convertible debentures issued to a non-resident associated enterprise turned on the appropriate benchmark for arm's length interest where the CCDs were denominated in Indian currency. Applying the governing precedent, it was held that such INR-denominated CCD interest must be benchmarked using domestic Prime Lending Rate (PLR) rather than foreign currency benchmarks. Consequently, the adjustment/addition made by the tax authorities on account of ALP computation of interest on the CCDs was held unjustified and was deleted, and the appeal was allowed. - ITAT
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