In the Judgment of Aurionpro Solutions Ltd. vs. ACIT, Range – 4(3), Mumbai, ITA No. 7872 (Mum.) of 2011, ITAT Mumbai has held that for purpose of determination of Arm’s Length Price, tested party is always assessee and not its Associate Enterprise (AE), LIBOR is acceptable for benchmarking loans given by Indian company to its foreign AEs, instead of interest rates prevailing in India.
The issue that whether in the case of amalgamation loss under the head of capital gain can be carry forward or not was a matter of discussion. In the Income Tax Act, 1961, there is no clarity in respect of this issue. However, in respect of business loss Section 72A of the Act was introduced […]
The thought of Winston Churchill, ‘It is always wise to look ahead, but difficult to look further than you can see’ means a lot. Sir Winston Leonard Spencer-Churchill was a British Conservative politician and statesman known for his leadership of the United Kingdom during the Second World War. Widely regarded as one of the greatest wartime leaders […]
Neither the capital receipts received by the Petitioner on issue of equity shares to its holding company, a non-resident entity, nor the alleged short-fall between the so called fair market price of its equity shares and the issue price of the equity shares can be considered as income within the meaning of the expression as defined under the Act.
This paper will emphasize that how the internal control will improve after the enactment of the new Companies Act. It will provide more power in the hands of the shareholder and the government. It is an attempt to focus on the Tightening of the Internal Controls thru the measures below: Self-Regulation, New Mechanism and organizations, Transparency and disclosures
