Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
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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