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Parent Company Subvention to Prevent Subsidiary Losses Is Capital Receipt: ITAT Pune
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taxguruin
AdvertisementNalco Water India Limited Vs ACIT (ITAT Pune) The appeal arose from the assessment order passed under Section 143(3) read with Section 144C(13) for AY 2012-13.
The assessee, engaged in manufacturing and trading water treatment chemicals, oilfield chemicals, industrial additives, and equipment, challenged transfer pricing adjustments of ₹7.95 crore, taxation of subvention received from its parent company, disallowance of depreciation on assets installed at customers’ premises, and several transfer pricing issues.
The principal issue concerned ₹65.19 crore received from the parent company,...