Income Tax – Disallowance of interest under Section 36(1)(iii) on interest-free advance to subsidiary SPV (AY 2015-16) - Respondent-assessee, engaged in the business development of roads, bridge and building on contract basis, advanced an interest-free loan to its subsidiary company while incurring...
Income Tax – Transfer pricing adjustment arising from change in filters and selection of comparables - Respondent-assessee filed the return of income and the case was selected for scrutiny. AO made an addition by adopting the arm’s length price determined by the TPO, who modified the filters, reject...
Income Tax – Expenditure on replacement of dies and moulds, Section 31, Appeal under Section 260-A by the Appellant (Revenue) for AY 2007-08 against the order of the Tribunal which held that the disallowance of expenditure on replacement of dies and moulds is to be allowed - Whether the Tribunal was...
Income Tax – Addition under Section 68/69A on account of unaccounted deposits in foreign bank account, Internal transfer of funds from one foreign bank account to another, Concurrent findings of fact - Search under Section 132 was carried out in the case of the Respondent-assessee and his family mem...
Income Tax – Corporate guarantee to associated enterprise as international transaction and rate of guarantee commission - Appellant extended corporate guarantee in favour of a bank to facilitate borrowing by its wholly owned foreign subsidiary, and the TPO held it to be an international transaction...