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          Income Tax

          Limitation of Interest Deduction - Section 94B

          Transfer Pricing Adjustments

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          Limitation of Interest Deduction restricts related party interest deductibility, with carryforward and specified exclusions. Limitation under Section 94B disallows deduction of interest and similar charges paid by an Indian company or PE to non resident associated enterprises to the extent of excess interest, determined by comparing total interest with an earnings based ceiling and interest paid to associated enterprises, with specified deemed debt rules for guarantees and deposits, exclusions for banking, insurance and qualifying IFSC finance companies, and a carryforward mechanism for disallowed amounts.
                            Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                              Provisions expressly mentioned in the judgment/order text.

                                  Limitation of Interest Deduction restricts related party interest deductibility, with carryforward and specified exclusions.

                                  Limitation under Section 94B disallows deduction of interest and similar charges paid by an Indian company or PE to non resident associated enterprises to the extent of excess interest, determined by comparing total interest with an earnings based ceiling and interest paid to associated enterprises, with specified deemed debt rules for guarantees and deposits, exclusions for banking, insurance and qualifying IFSC finance companies, and a carryforward mechanism for disallowed amounts.


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