https://www.taxtmi.com/caselaws?id=383620 The Tribunal partly allowed the appeal, remitting certain issues back to the Transfer Pricing Officer for reconsideration and directing the deletion of specific additions. The disallowance under Section 14A was partly sustained, with the Tribunal agreeing that no direct expenditure was incurred for investments made from internal accruals. The Tribunal emphasized that the arm's length price for management services cannot be Nil and directed the TPO to benchmark the transaction separately. The re-characterization of Compulsory Convertible Debentures as loans was rejected, following precedent to benchmark using the Prime Lending Rate. en-us Wed, 03 Jul 2019 00:00:00 +0530 Fri, 26 Jul 2019 16:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383620 The Tribunal partly allowed the appeal, remitting certain issues back to the Transfer Pricing Officer for reconsideration and directing the deletion of specific additions. The disallowance under Section 14A was partly sustained, with the Tribunal agreeing that no direct expenditure was incurred for investments made from internal accruals. The Tribunal emphasized that the arm's length price for management services cannot be Nil and directed the TPO to benchmark the transaction separately. The re-characterization of Compulsory Convertible Debentures as loans was rejected, following precedent to benchmark using the Prime Lending Rate. Case-Laws Income Tax Wed, 03 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383620