Fair-rent assessment requires consideration of lease terms, valuation principles and prevailing market rent; the certificate was quashed for fresh rev...
Document Identification Number compliance is satisfied when electronically communicated orders are promptly authenticated through a correctly identifi...
Industrial shrimp-feed machinery classification follows its commercial function, placing integrated production plants under the specific industrial fo...
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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