Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Where inter-company loans are advanced to subsidiary entities under the assessee's management and control, a higher arm's length interest rate is not justified merely because the loans are unsecured or the subsidiaries have a weaker credit profile. The Tribunal applied the principle noted in Bharti Airtel Limited and held that control over the subsidiary reduces, rather than increases, lending risk. It also found that the earlier accepted interest rates for the USA and Netherlands entities had not been disturbed in prior years and no fresh material showed any change in risk profile. The transfer pricing adjustment to the arm's length price of interest was therefore deleted.
Where inter-company loans are advanced to subsidiary entities under the assessee's management and control, a higher arm's length interest rate is not justified merely because the loans are unsecured or the subsidiaries have a weaker credit profile. The Tribunal applied the principle noted in Bharti Airtel Limited and held that control over the subsidiary reduces, rather than increases, lending risk. It also found that the earlier accepted interest rates for the USA and Netherlands entities had not been disturbed in prior years and no fresh material showed any change in risk profile. The transfer pricing adjustment to the arm's length price of interest was therefore deleted.
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