A Multifaceted Legal Analysis on Transfer Pricing and Tonnage Tax Scheme, Bareboat Charter, Interest on loan and other issues

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....rio, addressing numerous issues related to transfer pricing, tonnage tax scheme, and other tax-related matters. This detailed analysis is aimed at unpacking the intricacies of this case, focusing on the broader legal principles and their implications. Background The case emerged from an appeal by the Assistant Commissioner of Income Tax against the ruling of the Commissioner of Income Tax Appeal....

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....ovisions are not applicable to the operations covered under TTS, aligning with prior decisions and legislative intent​​. * Negative Lien as a Corporate Guarantee: * The Tribunal addressed whether the assessee's negative lien, akin to a corporate guarantee, should attract a fee. This discussion explored the risks involved and the need for a more nuanced approach to such financ....

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....or ships was another issue under scrutiny. The Tribunal's decision relied on its own prior rulings, emphasizing the principle of judicial consistency​​. * Allocation of Common Interest Expenditure: * The allocation of common interest expenditure between tonnage and non-tonnage tax activities was contested. The assessing officer's allocation was challenged, demonstrating t....