Section 92

Section 92

AAR : Whether the granting of loan amounting to Rs. 360 millions by the applicant, being a nonresident corporate assessee, in favour of Datex-Ohmeda (India) (P) Ltd. (hereinafter referred to as “Datex”), which is its wholly- owned subsidiary company incorporated in India, without charging any interest, and accordingly without adhering to the principles of arm’s length price, actually results in the Government exchequer or the tax revenue of the country being benefited ?

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Authority For Advance Rulings Instrumentarium Corporation, In Re Sections 92, 92(3), 245N(a), 245R(2), Proviso Syed Shah Mohammed Quadri, J., Chairman

Section 91, Section 92

Madras H.C : Whether on the facts and in the circumstances of the case, the Tribunal was right in holding that the sum of Rs. 15 lakhs due by the assessee to the Tamil Nadu Industrial Investment Corporation Ltd. as on 1st July, 1971, was includible in the capital base as provided in cl. (v) of r. 1 of the Second Schedule to the Companies (Profits) Surtax Act, 1964 ?

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High Court Of Madras CIT vs. Sakthi Sugars Ltd. Sections SURTAX Sch. II, r. 1(v), Indian Evidence Act, 1872, ss.

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