PCIT v. Vaibhav Global Ltd. (2023)453 ITR 31 (SC) Editorial : PCIT v. Vaibhav Global Ltd. (2023) 453 ITR 24 (Raj)(HC) is affirmed.

S. 92C : Transfer pricing-Arm’s length price -Adjustment on account of interest-free loans-Libor +2 Per Cent.-Corporate guarantee-Write-off of loss on account of investment in equity shares in subsidiary -Book profits -Provision for doubtful debts -No question of law -Order of High Court affirmed -SLP of Revenue is dismissed. [S. 92B, 115JB, Art. 136]

The High Court dismissed the Department’s appeal on the questions whether the Tribunal was justified in restricting the adjustment on account of interest-free loans advanced to associated enterprises to prevailing LIBOR +2 per cent., deleting the adjustment on account of corporate guarantee, allowing the write off of loss on account of investment in equity shares of one of its subsidiary, allowing the write-off of investment  for the purpose of computing “book profits” under section 115JB, remitting back the issues of disallowance out of provision for doubtful loans to a subsidiary and of disallowance out of bad debts provision claimed in minimum alternate tax to the Assessing Officer for verification.  SLP of Revenue is dismissed. (AY. 2009-10)