Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Taxability of interest under a flat buy-back arrangement turns on the actual repayment sequence and the income credited in the assessee's hands. Where documents, including the payer's email and remand material, showed that principal was to be repaid first and premium or interest only thereafter, the Assessing Officer could not treat the outstanding balance as interest already received or accrued without evidence that the full premium component had been paid. TDS credit was also noted as admissible only when the corresponding income is offered to tax, and the disputed addition was deleted.
Taxability of interest under a flat buy-back arrangement turns on the actual repayment sequence and the income credited in the assessee's hands. Where documents, including the payer's email and remand material, showed that principal was to be repaid first and premium or interest only thereafter, the Assessing Officer could not treat the outstanding balance as interest already received or accrued without evidence that the full premium component had been paid. TDS credit was also noted as admissible only when the corresponding income is offered to tax, and the disputed addition was deleted.
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