Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
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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