Home Highlights September 2012 Year 2012 This

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1. TP Adjustment - Benchmarking of interest receivable on loan - when the assessee has charged higher interest on loan to subsidiary compared to the prevailing interest...

2. Addition u/s 40A(2) - assessee has paid interest to certain related parties and treated interest rate @ 15% reasonable and disallowed excess rate paid to related parties...

3. 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...

4. 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...

5. Exemption from GST - upfront amount charged by the Applicant (as lease premium) for granting long-term lease of ninety years - The AAR concludes that long-term leases...

6. Disallowance of interest payment converted into FITL (Funded Interest Term Loans) - the impugned ‘funded interest term loan’ is not a loan transaction but assessee’s...

7. Exemption u/s 54EC - Assessee has not been able to raise any material contention to dispute this position. He has only submitted that the assessee wanted to invest the...

8. TPO and DRP have committed a fallacy, firstly, by considering the AE as a “tested party” and secondly, relying upon USD Corporate Bond Rates to benchmark the ALP of the...

9. Interest expenditure - assessee had availed loan at the interest rate of 12% p.a., whereas, it has advanced loan to a sister concern by charging 9% interest p.a - The...

10. TP Adjustment - rate of interest on loan availed from AE - when the prime lending rate itself had increased over the years and stood at 14.55% for the relevant period,...

11. Interest on refund - Rate of interest - The rate of interest is statutorily prescribed under section 27 (A) read with Notification issued there under according to which...

12. Disallowance of claim of interest expenses u/s. 57(iii) - The Assessing Officer (AO) had disallowed a portion of the interest expenses based on the difference between...

13. Rate of tax on sale of depreciable assets - STCG vs LTCG - as per Section 112 of the Act, the tax on long term capital gains on transfer of a long term capital asset is...

14. 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...

15. Interest on delayed refund at notified rate of interest (6%) to the appellant - enhanced rate of interest - The Commissioner (Appeals) has relied on the decision of...