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. Real estate development company advanced loans to its Indian subsidiary for funding step-down foreign subsidiaries undertaking real estate projects. Interest paid on...

5. 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...

6. 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...

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

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

9. TP adjustment of interest - CIT(A) confirmed upward adjustment towards interest by adopting rupee loan rate instead of LIBOR linked rate in respect of foreign currency...

10. 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...

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

12. Addition of interest on interest free loans advanced by assessee Company to sister concerns/related parties disallowed. Onus on assessee to prove commercial expediency...

13. 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...

14. 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...

15. 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...