Foreign portfolio investment liberalisation extends listed equity access to all individual persons resident outside India, subject to limit monitoring...
The Tribunal deleted the transfer pricing adjustment on corporate guarantee fee, holding that 0.25% was already accepted in the assessee's own earlier years and the higher rate was unsupported. It also deleted the adjustment on software cost allocation, rejecting re-characterisation of a cost-to-cost transaction as intra-group services. For electricity transfer pricing, it held that SEB rates were the proper benchmark and remanded the matter for verification and fresh determination. The duplicate disallowance under section 80-IA was held unsustainable, and the section 14A disallowance was deleted because no exempt income was earned. The section 115JB adjustment on education cess and interest under section 234A were both remanded for fresh verification.
The Tribunal deleted the transfer pricing adjustment on corporate guarantee fee, holding that 0.25% was already accepted in the assessee's own earlier years and the higher rate was unsupported. It also deleted the adjustment on software cost allocation, rejecting re-characterisation of a cost-to-cost transaction as intra-group services. For electricity transfer pricing, it held that SEB rates were the proper benchmark and remanded the matter for verification and fresh determination. The duplicate disallowance under section 80-IA was held unsustainable, and the section 14A disallowance was deleted because no exempt income was earned. The section 115JB adjustment on education cess and interest under section 234A were both remanded for fresh verification.
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