Soma Textile & Industries Ltd. v. Asst.ClT

59 Taxmann.com 152Income Tax Appellate Tribunal2015#5599 most cited

What is Soma Textile & Industries Ltd. v. Asst.ClT authority for?

The comparable uncontrolled price for quasi-capital loans cannot be nil unless it is for a transitory period offering capital investment opportunity or other such benefits.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2020 to 2024.

Also referred to as

Soma Textile & Industries Ltd. v. Asst.CIT · ITAT · transfer pricing · quasi-capital loan · arm's length price · comparable uncontrolled price · section 92F · section 92(1)

Also reported as

154 ITD 745

Issues it is cited on

section 80iesection 35(1)(iv)section 92f(ii)section 10(2a)section 92(1)section 35(1)legal expensesstrategic investmentsection 92faccumulated profitsweighted deductionsection 35(2ab)

Judgments citing Soma Textile & Industries Ltd. v. Asst.ClT

Bombay Rayon Holdings Limited, Mumbai vs. ITO-9(2)(2), Mumbai

In the result, appeals of the assessee are partly allowed

ITA 5986/MUM/2018[2009-10]Status: DisposedITAT Mumbai06 Jan 2020AY 2009-10

Bench: Shri Shamim Yahya & Shri Pawan Singh

For Appellant: Shri. Madhur Agrawal, Shri Ajit KumarFor Respondent: Shri. Anand Mohan
Section 131Section 133Section 143(3)Section 144CSection 144C(13)Section 148Section 92(1)Section 92C(1)

…rcumstances of the case, are not part of shareholder activities. M/s. Bombay Rayon Holdings Ltd., 17. It also referred to the reliance placed by the assessee on the decision of ITAT Ahmadabad bench in the case of Soma Textiles & Industries Ltd. vs. Addl. CIT 59 Taxmann.com 152. It noted that in the said decision it was held that of quasi capital cannot be nil. It was also held that comparable uncontrolled price of a quasi capital loan, unless it is only for a transitory period and the defact reward for this value of money is the opportunity for capital investment or such other benefit, cannot be nil. Referring t…