Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights December 2016 Year 2016 This

When the DRP itself stated that since Indian banks were charging ...

Income Tax

December 30, 2016

When the DRP itself stated that since Indian banks were charging 250 basis points above LIBOR on similar loans, there was no good reason for holding that the loan advanced to a subsidiary at 247 basis points above the LIBOR rate to be not at arm’s length. - HC

View Source

 


 

You may also like:

  1. TP Adjustment - arm’s length price of interest on short term loan granted to the AE - The fact that the assessee has provided a short term loan only for a period of 15...

  2. TP adjustment to payment of interest on ECB loan - TPO himself has stated that while granting permission to the assessee for availing ECB loan, the RBI has fixed the...

  3. Banking and other financial services - RCM - So far the SWIFT charges are concerned, the privity of contract is between the Indian Bank and the SWIFT society. Thus, the...

  4. Appropriate rate for benchmarking - receivables from AEs - it would be most appropriate if the LIBOR rate is applied as most appropriate rate of interest for imputing...

  5. Liability of service tax - reverse charge mechanism - overseas banks has deducted certain bank charges from the export realization of the appellant’s export - Even...

  6. Banking and other Financial Services - reverse charge mechanism - The foreign banks while remitting the money to the Indian Bank, deduct their charges for collection of...

  7. Levy of service tax - business auxiliary service or not - The Indian Bank has only collected such charges from the appellant as a reimbursement which was born by the...

  8. TP Adjustment - Impute interest on receivables - LIBOR + 200 basis point rate is most appropriate rate and hence, direct the AO/TPO to adopt LIBOR + 200 basis point for...

  9. Foreign Banks Charges - liability of service tax - reverse charge mechanism - Indian Banks are recipient of service, therefore, the appellant cannot be held as recipient...

  10. Reverse charge mechanism - The act of deduction of an amount as charges for transfer of the foreign exchange to the Indian bank from the sale proceeds of the appellant...

  11. Transfer pricing adjustment - advance to subsidiary - even though this interest rate could reach upto 400 basis points in some cases, there cannot be any good reason...

  12. Unexplained money u/s 69A - Unexplained loan - the loan creditors had deposited cash in their accounts and mostly on the very same day they had transferred the same to...

  13. Restraint from selling or alienating the property - Priories of secured creditors over State against tax dues - In the present case, it is clear that the charge that...

  14. Ex-parte order by CIT (Appeals) - Section 250(6) enjoins that the CIT(A) shall state the points for determination before it and the decision shall be rendered on such...

  15. Reverse charge mechanism - Banking & other financial services - recipient of services or not - services provided by the Foreign Banks situated outside India - The...

 

Quick Updates:Latest Updates