Unlawful outward remittances via Hawala using proforma invoices and electronic records proved; documents admitted, directors penalised, penalties redu...
Attachment of equivalent-value properties as proceeds of crime upheld; preventive attachment order and confirmation sustained; no independent ED reinv...
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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