Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
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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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