https://www.taxtmi.com/caselaws?id=448150 Under the tonnage tax regime, qualifying shipping income is computed on the statutory tonnage basis, so transfer pricing adjustments to ship acquisition interest and hire charges were held inapplicable and the deletion was sustained. The negative lien fee, treated as a corporate guarantee, was benchmarked at 0.25% on the facts and that rate was affirmed. Interest earned on inter-corporate and bank deposits was treated as business income, and the related interest cost was allowable under section 36(1)(iii), or alternatively section 57(iii). Common interest expenditure was to be apportioned by assets employed, not turnover, and the turnover-based disallowance was rejected. en-us Tue, 09 Jan 2024 00:00:00 +0530 Thu, 11 Jan 2024 11:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448150 Under the tonnage tax regime, qualifying shipping income is computed on the statutory tonnage basis, so transfer pricing adjustments to ship acquisition interest and hire charges were held inapplicable and the deletion was sustained. The negative lien fee, treated as a corporate guarantee, was benchmarked at 0.25% on the facts and that rate was affirmed. Interest earned on inter-corporate and bank deposits was treated as business income, and the related interest cost was allowable under section 36(1)(iii), or alternatively section 57(iii). Common interest expenditure was to be apportioned by assets employed, not turnover, and the turnover-based disallowance was rejected. Case-Laws Income Tax Tue, 09 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448150