International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
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Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Clause (e) of section 43B, as amended to include interest payable to co-operative banks effective 01-04-2018, does not apply to assessment year 2017-18 unless the assessee qualified as a scheduled bank; a notified scheduled bank was already covered pre-amendment. Because the assessee did not pay interest due to Punjab and Maharashtra Co-operative Bank on or before the due date for filing under section 139(1), the interest is disallowable under section 43B. Capitalization of such interest into work-in-progress does not prevent the disallowance; decision favours revenue.
Clause (e) of section 43B, as amended to include interest payable to co-operative banks effective 01-04-2018, does not apply to assessment year 2017-18 unless the assessee qualified as a scheduled bank; a notified scheduled bank was already covered pre-amendment. Because the assessee did not pay interest due to Punjab and Maharashtra Co-operative Bank on or before the due date for filing under section 139(1), the interest is disallowable under section 43B. Capitalization of such interest into work-in-progress does not prevent the disallowance; decision favours revenue.
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