Reverse charge and assignment of royalty collection: exemption for excess royalty collectors subject to reconciliation; leaseholders remain liable und...
Authorization requirements for customs brokers and benami shipping bills: tribunal upholds licence revocation and penalties after COVID time limit fou...
Eligibility for notification exemption on imported fertilizers challenged; penalty, interest and confiscation set aside after voluntary payment and no...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
