Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Certified segmental financials used in transfer pricing documentation could not be rejected merely for differing from AS-17 audited segment disclosure where the assessee explained the allocation method and no specific defect was found; the issue was remitted for fresh consideration. ECB interest at LIBOR plus 3% was held to be at arm's length because the borrowing had RBI approval and the TPO made only ad hoc substitution without proper comparability analysis. Outstanding receivables from AEs were treated as an international transaction, and interest was directed to be recomputed invoice-to-invoice at LIBOR plus 200 basis points in line with earlier years. The direction to verify brought-forward amalgamation losses and allow them according to law was upheld.
Certified segmental financials used in transfer pricing documentation could not be rejected merely for differing from AS-17 audited segment disclosure where the assessee explained the allocation method and no specific defect was found; the issue was remitted for fresh consideration. ECB interest at LIBOR plus 3% was held to be at arm's length because the borrowing had RBI approval and the TPO made only ad hoc substitution without proper comparability analysis. Outstanding receivables from AEs were treated as an international transaction, and interest was directed to be recomputed invoice-to-invoice at LIBOR plus 200 basis points in line with earlier years. The direction to verify brought-forward amalgamation losses and allow them according to law was upheld.
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