HC: Admits appeal challenging Instrumentarium Corporation SB-decision confirming TP-adjustment on inbound loan

Jun 25,2019

Calcutta High Court admits Instrumentarium Corporation’s (Assessee) appeal against Special Bench (SB) decision wherein it was held that TP adjustment could be made u/s 92 in respect of the interest free loan granted by overseas non-resident entity to its Indian subsidiary (AE); Special Bench had ruled in Revenue's favour after rejecting assessee's Indian tax base erosion theory holding that, Revenue is entitled to make TP-adjustment in respect of the interest-free loan; ...


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