2017 (2) TMI 1362

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.... "(a) Whether on the facts and in the circumstance of the case and in law, the Tribunal was correct in treating lending transaction on part with borrowing transaction in contravention to the provision of Section 92B, thereby overlooking crucial facts of opportunity cost and risk borne by the leading entity which is resident of India as distinguished from the transactions where lender is not resident in India? (b) Whether on the facts and in the circumstance of the case and in law, the Tribunal was right in directing the A. O. to benchmark the interest at prevailing LIBOR rate instead of rupee loan rate compute the Arms Length interest on the loan advanced by the assesssee to its AE, ignoring the fact that LIBOR does not gov....

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....ncentive; or u/s. 194C of the Income Tax Act, 1961 as part of contract or performance under an agreement between the principal and the dealer? (f) Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in deleting the disallowance of deduction of Rs. 28.39 lakh being reversal of 'provision for medical benefits' disallowed in earlier years, when the assessee is before the appellate authorities on the disallowance of such provision claimed in such previous years, and the disallowance during the year is only consequential?" (g) Whether on the facts and in the circumstance of the case and in law, the Tribunal was correct in setting aside the disallowance made u/s. 40(a)(ia) relyi....