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2017 (12) TMI 468 - AT - Income TaxInterest on loan given to the subsidiary - Held that:- No adjustment was made on account of interest on loan given to the subsidiary for assessment year 2009-10, we are of the considered opinion that no addition is called for on account of difference in arm’s length price on the transaction on account of interest on loan given to the subsidiary. The grounds raised by the assessee are accordingly allowed. Addition on account of the interest on export proceeds receivable - rectification application u/s 154 - Held that:- We find the rectification application filed before the Assessing Officer u/s 154 is pending. It is the submission of the ld. counsel for the assessee that there was some calculation error and there is no international transaction at all on account of receivables. Considering the totality of the facts of the case and considering that the rectification application is pending before the Assessing Officer which is yet to be disposed of, we deem it proper to restore this issue to the file of the Assessing Officer for fresh adjudication. The grounds no.7 and 8 are accordingly allowed for statistical purposes.
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