Promissory note presumption of consideration survives blank-signature and income-tax non-disclosure objections when admissions and attesting evidence ...
Charitable registration cancellation: limitation and jurisdiction upheld, but withdrawal quashed under discontinued provisions for skill-development e...
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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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