Minimum Public Offer Requirements set tiered issuer-based allotment minima with mandatory staged public shareholding increases and exchange enforcemen...
Disallowance under tax law for investment expenses cannot be applied mechanically; authority must record clear reasons before increasing assessee's su...
Additional evidence bearing directly on the transfer pricing adjustment for interest on a loan to an associated enterprise was admitted, including the independent auditor's report, the RBI correspondence and order, and a Hamburg District Court liquidation order. As the subsidiary was stated to be incurring persistent losses and under liquidation, the existing 6% interest adjustment was held unsustainable without examining these materials. The matter was remitted to the Assessing Officer for fresh adjudication in accordance with law after giving the assessee an opportunity of hearing, and no final ruling on the merits of the adjustment was made.
Additional evidence bearing directly on the transfer pricing adjustment for interest on a loan to an associated enterprise was admitted, including the independent auditor's report, the RBI correspondence and order, and a Hamburg District Court liquidation order. As the subsidiary was stated to be incurring persistent losses and under liquidation, the existing 6% interest adjustment was held unsustainable without examining these materials. The matter was remitted to the Assessing Officer for fresh adjudication in accordance with law after giving the assessee an opportunity of hearing, and no final ruling on the merits of the adjustment was made.
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