Pre-trial bail granted where custodial period, documentary prosecution, and magistrate-triable offence favor release subject to surety and no witness ...
Allowability of Salary Exemptions: Form 16 entries can substantiate HRA and other salary exemptions, and home loan interest is deductible for a self-o...
Capital gains exemption: payment for plot, architect fees and bona fide commencement of construction can satisfy utilisation requirement and secure re...
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.
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