25 results for “transfer pricing”+ Section 80P(4)clear
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In the result appeal of the assessee is partly allowed
Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Mufg Bank Ltd, Vs. Acit (International Taxation), 5Th Floor, Worldmark 2, Asset 8, Circle-2(2)(1), Aerocity, Nh-8, New Delhi New Delhi Pan: Aabct3880D (Appellant) (Respondent)
transfer pricing addition on account of the corporate guarantee commission of ₹ 103,485,509/– iii. disallowance u/s 14 A of the income tax act of ₹ 22,521,366/– iv. charge of interest on external commercial borrowing of ₹ 518,00,31,066 to be taxed at the rate of 10% as per the provisions of article 11 of the Double Taxation