Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
In transfer pricing proceedings concerning interest on rupee-denominated non-convertible debentures issued to an associated enterprise, the ITAT upheld 10% as the arm's length rate because the same instruments had already been examined in the first year and the TPO had accepted that rate using SBI PLR as the benchmark for rupee-denominated instruments. The Tribunal also noted that payment and redemption were in Indian currency, supporting the CIT(A)'s acceptance of the rate. Revenue's challenge to deletion of the transfer pricing adjustment was rejected. The Tribunal further corrected the interest quantum to be adopted for the year, directing use of Rs. 8,27,24,756 as the proper amount.
In transfer pricing proceedings concerning interest on rupee-denominated non-convertible debentures issued to an associated enterprise, the ITAT upheld 10% as the arm's length rate because the same instruments had already been examined in the first year and the TPO had accepted that rate using SBI PLR as the benchmark for rupee-denominated instruments. The Tribunal also noted that payment and redemption were in Indian currency, supporting the CIT(A)'s acceptance of the rate. Revenue's challenge to deletion of the transfer pricing adjustment was rejected. The Tribunal further corrected the interest quantum to be adopted for the year, directing use of Rs. 8,27,24,756 as the proper amount.
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