TP Adjustment - Interest on interest outstanding/interest ...

Interest on Unpaid Loan Enhances Liquidity, Justifies TPO Charging Interest as Outstanding Loan Under Transfer Pricing Rules.

July 21, 2023

Case Laws Income Tax AT

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 assessee to its AE and the interest element on the said loan if not paid improves the liquidity position of the AEs and become part and parcel of the said loan transaction. Therefore, no infirmity in the action of the TPO in treating the interest receivable as a loan outstanding and charging interest on the same accordingly. - AT

View Source

← Previous Next →

TP Adjustment - Interest on interest outstanding/interest ...

Interest on Unpaid Loan Enhances Liquidity, Justifies TPO Charging Interest as Outstanding Loan Under Transfer Pricing Rules.

July 21, 2023

Case Laws Income Tax AT

You may also like:

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...

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...

Section 43B of the Income Tax Act disallows certain deductions for unpaid statutory dues like interest, tax, duty, etc. The key points are: Unpaid interest on loans from...

Disallowance on interest u/s. 36(1)(iii) - AO has compared the payment of interest @ 12%/15% on the unsecured loan obtained by the assessee with the interest amount...

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...

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...

Interest on refunds u/s 244A - unpaid portion representing tax as well as interest - The assessee is entitled for interest on unpaid interest.

ITAT upheld revision under s.263 finding assessment order erroneous and prejudicial to revenue interests. Assessee failed to establish loan genuineness and lenders'...

Deemed dividend u/s 2(22)(e) is not taxable in the hands of the assessee company if it is not a shareholder in the companies that extended loans. It is chargeable to tax...

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

Enhanced Compensation – Interest on enhanced compensation - Waiver of Interest - assessee was entitled for waiver of interest till the date of receipt of enhanced...

TP adjustment - notional interest - short term advances made by the assessee to its associated enterprises - The assessee being unable to establish with evidence the...

TP Adjustment - Addition of interest expenses - These clauses in the loan agreement are nothing but eye-wash as the appellant company is the holding company of the...

Entitled to registration u/s 12AA and approval under Section 80G - Allegation of charging higher rate of interest from the self help groups in the name of charitable...

A recent circular addressed the taxability of loans between related parties or affiliates. The circular clarifies that providing loans between related parties...

Quick Updates: