Change of corporate management after approved resolution plan - writ maintainable; property attachment not 'transfer' under PBPT; Section 32A protecti...
Annuloplasty band classification as implanted therapeutic appliance, not anatomical replacement, resulting in classification under tariff heading for ...
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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