Arms length pricing discovery has just been made more easier for TPOs as their power have been enhanced by Finance Bill 2011-12. The Bill has increased the power of transfer pricing officer by amendment and insertion of clauses and sub clause of Section 92CA of the I T Act. Here are the proposed power enhancement [...]
Can notional interest be taxed under transfer pricing law ?
May 18, 2010 by
Yes, under transfer pricing mechanism , there is scope of notional interest taxation. This is held by Delhi bench F in Perot Systems TSI ( India) Ltd. vs. DCIT, ITA No. 2320 to 2322/Del/08, Delhi Bench ‘F’ order dated 30.10.2009. Facts of the case The aseessee, an India company, advanced interest free loans to its 100% foreign subsidiaries....
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