https://www.taxtmi.com/caselaws?id=420877 Share application money remitted to associated enterprises for equity allotment could not be re-characterised as debt, so no notional interest transfer pricing adjustment was justified. Advances recoverable from associated enterprises were to be benchmarked at LIBOR plus 300 basis points, with interest confined to the net delayed period after the agreed credit period. The section 14A disallowance required fresh factual examination, but it could not be mechanically added back to book profit under section 115JB. Foreign tax credit on dividend income was allowable under the Indo-Cyprus treaty, and interest under sections 234A, 234B and 234C was to be recomputed in accordance with law. en-us Wed, 06 Apr 2022 00:00:00 +0530 Sat, 20 Jun 2026 13:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=420877 Share application money remitted to associated enterprises for equity allotment could not be re-characterised as debt, so no notional interest transfer pricing adjustment was justified. Advances recoverable from associated enterprises were to be benchmarked at LIBOR plus 300 basis points, with interest confined to the net delayed period after the agreed credit period. The section 14A disallowance required fresh factual examination, but it could not be mechanically added back to book profit under section 115JB. Foreign tax credit on dividend income was allowable under the Indo-Cyprus treaty, and interest under sections 234A, 234B and 234C was to be recomputed in accordance with law. Case-Laws Income Tax Wed, 06 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=420877