Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
Page of 4803
Press 'Enter' after typing page number.
4221 to 4240 of 96047 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT held that no transfer pricing adjustment could be made on interest-free loans advanced to associated enterprises where the assessee had not commenced business, had capitalised all expenditure as work-in-progress, and had earned no income during the year. On those facts, there was no factual basis to infer profit shifting from the assessee to its holding company or group entities, and the proposed interest imputation under transfer pricing principles was unsustainable. The Tribunal also accepted that the related contention on specified domestic transaction treatment was covered by the same reasoning. The transfer pricing adjustment was deleted and the appeal was allowed.
The ITAT held that no transfer pricing adjustment could be made on interest-free loans advanced to associated enterprises where the assessee had not commenced business, had capitalised all expenditure as work-in-progress, and had earned no income during the year. On those facts, there was no factual basis to infer profit shifting from the assessee to its holding company or group entities, and the proposed interest imputation under transfer pricing principles was unsustainable. The Tribunal also accepted that the related contention on specified domestic transaction treatment was covered by the same reasoning. The transfer pricing adjustment was deleted and the appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
