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. Capital gains tax exemption bonds issued u/s 54EC of the Income Tax Act, 1961, are long-term specified assets with a mandatory lock-in period of 5 years. The legislative...

3. 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...

4. 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...

5. 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...

6. Capital gains taxation streamlined with short-term gains on certain financial assets attracting 20% tax and long-term gains on all assets attracting 12.5% tax. Exemption...

7. The TPO benchmarked the ECB transaction using CUP method and SBI base rate as CUP, but failed to consider factors like credit rating, future revenue projections, and...

8. 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...

9. 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...

10. 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...

11. 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...

12. 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...

13. 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...

14. 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,...

15. Regarding long-term capital gain determination, indexed cost of acquisition claimed by assessee at Rs. 45 lakhs for property valued over Rs. 45 lakhs, evidenced by...