Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
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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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