Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Transfer pricing of interest on external commercial borrowings must be benchmarked on the correct factual and contractual terms for each year. For ECB1, the lender's assignment, change in jurisdiction, shift from floating to fixed interest for part of the year, and extension of maturity materially affected comparability, so the ALP issue was remitted for fresh determination. The RBI all-in-cost ceiling was held to be only a regulatory cap and a corroborative factor, not a substitute for ALP determination under transfer pricing rules. For ECB2, the Tribunal found incorrect use of floating-rate comparables and failure to consider the assessee's Bloomberg-based study, so the ALP was also set aside for fresh benchmarking.
Transfer pricing of interest on external commercial borrowings must be benchmarked on the correct factual and contractual terms for each year. For ECB1, the lender's assignment, change in jurisdiction, shift from floating to fixed interest for part of the year, and extension of maturity materially affected comparability, so the ALP issue was remitted for fresh determination. The RBI all-in-cost ceiling was held to be only a regulatory cap and a corroborative factor, not a substitute for ALP determination under transfer pricing rules. For ECB2, the Tribunal found incorrect use of floating-rate comparables and failure to consider the assessee's Bloomberg-based study, so the ALP was also set aside for fresh benchmarking.
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