https://www.taxtmi.com/caselaws?id=389487 Transfer pricing guidance favours aggregation of closely linked intra-group transactions under TNMM where corporate charges form part of overall operating activity, rejects benchmarking foreign currency loans by domestic lending rates instead of LIBOR-based rates, and excludes notional interest on delayed trade receivables treated as business sales rather than deemed loans. The note also supports depreciation on goodwill arising from amalgamation, deductibility of ESOP reimbursement as employee compensation, allowance of land-transfer expenses in capital gains computation, and acceptance of actual share-sale consideration without notional substitution. TDS credit, MAT credit and interest under sections 234A, 234B and 234C are subject to verification or consequential treatment. en-us Fri, 29 Nov 2019 00:00:00 +0530 Mon, 09 Dec 2019 14:51:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=389487 Transfer pricing guidance favours aggregation of closely linked intra-group transactions under TNMM where corporate charges form part of overall operating activity, rejects benchmarking foreign currency loans by domestic lending rates instead of LIBOR-based rates, and excludes notional interest on delayed trade receivables treated as business sales rather than deemed loans. The note also supports depreciation on goodwill arising from amalgamation, deductibility of ESOP reimbursement as employee compensation, allowance of land-transfer expenses in capital gains computation, and acceptance of actual share-sale consideration without notional substitution. TDS credit, MAT credit and interest under sections 234A, 234B and 234C are subject to verification or consequential treatment. Case-Laws Income Tax Fri, 29 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=389487