Duplicate PAN cancellation timeframe requires prior administrative representation before judicial intervention, ensuring a time-bound decision on the ...
Natural justice and pre-CIRP labour awards protect termination compensation, permitting withdrawal of court deposits despite later insolvency resoluti...
Arbitration of SEZ sub-lease monetary claims preserves rent, maintenance, termination, improvements and damages disputes while unused premises are vac...
Scientific research approval grants a research association tax recognition, subject to annual donor reporting, certification, and regulatory complianc...
Internal comparable pricing of interest on compulsorily...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for transfer-pricing purposes.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Internal comparable pricing of interest on compulsorily convertible debentures applied where subscriptions under the same agreement carried identical material terms and no relevant change was established. The comparable supported acceptance of the 15% interest rate as arm's length and deletion of the transfer-pricing adjustment based on treating the debentures as equity. Interest disallowance for payments to a foreign associated enterprise required factual verification of the correct associated-enterprise interest. Set-off of brought-forward business losses likewise required verification of quantum, availability, and appellate effect. A challenge solely to initiation of penalty proceedings was premature.
Internal comparable pricing of interest on compulsorily convertible debentures applied where subscriptions under the same agreement carried identical material terms and no relevant change was established. The comparable supported acceptance of the 15% interest rate as arm's length and deletion of the transfer-pricing adjustment based on treating the debentures as equity. Interest disallowance for payments to a foreign associated enterprise required factual verification of the correct associated-enterprise interest. Set-off of brought-forward business losses likewise required verification of quantum, availability, and appellate effect. A challenge solely to initiation of penalty proceedings was premature.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4912 
