Home Highlights April 2013 Year 2013 This

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1. Transfer Pricing Adjustment - Adjustment on account of notional interest on the receivables - when the assessee is having their own funds and not paying interest on any...

2. Transfer pricing adjustment - No interest having been charged by the assessee to the non-AE outstandings, its transaction of outstanding receivables with AE without...

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

4. Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

5. Adjustment of part income-tax refund received by the assessee against the total outstanding refund, comprising of principal/ tax and interest - quantum of interest to...

6. Interest on delayed refund - seizure of cash / currency during search - The Commissioner (Appeals) has committed an error while holding that since there is no provision...

7. 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...

8. Addition made u/s 153A on account of undisclosed foreign bank account and interest income thereon - assessee confronted with client profiles from HSBC Bank showing...

9. TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

10. Interest charged u/s 234B - Deposit of amount pursuant to search and seizure proceedings - Provisions of section 132B of the Act governs the manner of utilisation of...

11. TP Adjustment - non granting of adjustment on import duty - as necessary consumption of the material is only booked in the profit and loss account for which the...

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

13. Validity of Intimation passed u/s 143(1) - Rectification of arithmetical error or prima facie incorrect claim - CPC is entitled to make adjustments as per 1st proviso of...

14. Income from the nature of interest received by the assessee in DRDO/ISRO accounts (for short ‘FD A/cs’) - the assessee, DRDO/ISRO are either Government Departments or...

15. Assessee is entitled to adjustment of seized amount towards advance tax liability from the date of making the application in that regard. The Tribunal has rightly held...