Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
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 
TaxTMI 
of 4817 
Join Channel 
