Transfer pricing adjustment on quasi-equity transaction like ...
Transfer pricing adjustments & benchmarking required for quasi-equity transactions. Lease accounting differs for operating & finance leases. ESOP expenses deductible.
Case Laws Income Tax
July 23, 2024
Transfer pricing adjustment on quasi-equity transaction like non-convertible cumulative redeemable preference shares necessitates benchmarking cost with international LIBOR rates considering risk factors. Lease accounting principles differ for operating and finance leases; depreciation allowable on assets under finance lease. Employees' share option scheme expenses deductible subject to fulfillment of conditions. Disallowance u/s 14A restricted to investments yielding exempt income. Section 14A disallowance excluded from book profit computation u/s 115JB. Cash deposits during demonetization by authorized forex dealer requires substantiation. Depreciation allowable on property despite temporary letting if used for business. Indexation benefit available while computing book profit u/s 115JB.
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