Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
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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