Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
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Transfer pricing adjustment on overdue receivables was upheld only in principle, but recomputation was ordered on the basis of a 90-day credit period, verification of comparable credit terms, correction of receipt dates, and fresh benchmarking of the arm's length interest rate through proper FAR analysis. The plea that no interest could be imputed to a debt-free entity was rejected, and the working capital adjustment argument failed because no such adjustment had been claimed in the transfer pricing study. The Tribunal also directed deletion of the double addition for foreign exchange loss, correction of the mismatch between assessed income and the computation sheet, and grant of TDS and foreign tax credit. Interest under section 234A was deleted because the return was filed within the extended due date.
Transfer pricing adjustment on overdue receivables was upheld only in principle, but recomputation was ordered on the basis of a 90-day credit period, verification of comparable credit terms, correction of receipt dates, and fresh benchmarking of the arm's length interest rate through proper FAR analysis. The plea that no interest could be imputed to a debt-free entity was rejected, and the working capital adjustment argument failed because no such adjustment had been claimed in the transfer pricing study. The Tribunal also directed deletion of the double addition for foreign exchange loss, correction of the mismatch between assessed income and the computation sheet, and grant of TDS and foreign tax credit. Interest under section 234A was deleted because the return was filed within the extended due date.
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