Home Highlights August 2014 Year 2014 This

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1. Disallowance of amount of interest on the amount advanced as interest-free advance & loans - Assessee on one hand is advancing interest free loans and advances to his...

2. Disallowance of notional interest under TP - TPO had re-characterised the transaction of subscription of shares into advancing of unsecured loans - Nothing is brought on...

3. Deemed dividend u/s 2(22)(e) - assessee is a major share holder in loan granting company - Advance given for purchase of property - The words “loans or advances”...

4. Addition of interest attributable on the diversion of loan fund - Once own fund of the assessee exceeds the amount of interest free loans and advances, then a...

5. Disallowance of interest on the advance - Simply because the assessee has secured loan from Standard Chartered Bank that does not mean that same interest bearing fund...

6. Disallowance of Interest Expenses related to Interest free Advance/loan given to its subsidiary company - The loan advanced to subsidiary company is financed from...

7. Disallowance of interest u/s 36(1)(iii) towards interest expenditure - allegation that assessee company diverted its “interest bearing funds” for giving “interest free...

8. TP Adjustment - Interest on interest outstanding/interest receivable - The interest on a loan is a compensation received towards the utilisation of funds given by the...

9. TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

10. Assessment of notional interest on loans - loan has been granted by the assessee to its sister concern - As per the provisions of Sec. 36(1)(iii) AO could have...

11. TP Adjustment - Interest on loans and advances given to the AEs - Interest rates vary and are thus dependent on the foreign currency in which the repayment is to be made...

12. Additions made on notional interest on loans & advances - AO has completely erred in imputing notional interest on loans & advances. As the argument of the assessee that...

13. Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

14. Characterization of receipts - Treatment of interest income from staff loans and advances, interest income from other loans and advances and miscellaneous income -...

15. TP Adjustment - Notional interest - interest-free advances extended by the assessee to its AE - In an uncontrolled condition and between persons other than associated...