Search Results Page
Search Results
1 - 8 of 8 (0.19 seconds)Section 115JB in The Income Tax Act, 1961 [Entire Act]
The Finance Act, 2018
Section 115J in The Income Tax Act, 1961 [Entire Act]
Pr. Commissioner Of Income Tax -4 vs Harinagar Sugar Mills Ltd on 10 June, 2019
32. Dr. Saraf, learned senior counsel for the sole respondent, in this connection, has
relied upon the decision of the High Court of Judicature of Bombay in the case
of Commissioner of Income Tax-IV v. Harinagar Sugar Mills Ltd. [order, dated
04.01.2017, in Income Tax Appeal No. 1132/2014]. The High Court of Bombay, in the
said decision, on consideration of a similar issue, proceeded to draw the following
conclusions:
The Companies Act, 1956
Hind Securities Services And House ... vs Ito, Ward-28(5), Delhi on 25 April, 2022
i) In the case of Everest Kento Cylinder Ltd (Supra), assessee's AE availed loan
from ICICI Bank for which assessee gave corporate guarantee. The loan was for
working capital as well as capital expenditure. Assessee had charged guarantee
commission @ 0.5%. The AO took external comparable and benchmarked the
rate at 3%. Before the Hon'bie Tribunal, it was stated that assessee itself paid
0.6% to ICICI Bank for guaranteeing a separate loan for assessee. Hon'bie
Tribunal took the view that 0.5% guarantee fee is reasonable in view of the fact
that rate of interest paid by AE was much lower than interest paid by assessee
itself. TP adjustment made by TPO was accordingly deleted.
Section 92B in The Income Tax Act, 1961 [Entire Act]
1