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Transaction of providing loan to foreign AE at a higher rate than LIBOR was at ALP
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International Tax
Transaction of providing loan to foreign AE at a higher rate than LIBOR was at ALP
Posted on
on
February 13, 2015
Tenet Tax Daily February 13 2015
By
tenettax-team
International Tax
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Assessment order was invalid as it was issued on basis of time barred notice under sec. 143(2)
No reassessment after 4 years to disallow sums paid to NR if assessee had already disclosed all material facts