TP Adjustment - regional management services received by the ...

Case Laws Income Tax

February 20, 2021

TP Adjustment - regional management services received by the assessee - incorrect factual observations and invalid of assumption of jurisdiction by the TPO who without following any of the methods provided in Sec.92C had determined the arm‟s length price of the transaction of receipt of regional management services by the assessee from its domestic AE at Nil - pricing adjustment made by the TPO vacated - AT

View Source

← Previous Next →

TP Adjustment - regional management services received by the ...

Case Laws Income Tax

February 20, 2021

You may also like:

TP Adjustment - intra/group services in the nature of management services - DRP ignored the evidences filed by the assessee demonstrating receipt of management services...

TP Adjustment - international transaction of `Payment of Regional Service charges (RSC)’ - TPO has referred to regional services being in the nature of shareholder...

TP adjustment in respect of management fee - When the TPO alleges that the assessee has not received any of the above services, it would indicate that the very...

TP Adjustment on account of the Management fees and payment of R&D expenses - As regards, failure of the Assessee to provide service wise break-up of management fee, the...

TP Adjustment - apportioning the expenses of assessee’s affiliates - Also noted that the assessee has received certain services from its AE which has been treated by the...

TP Adjustment - Addition as ‘Fees for Technical Services’ ignoring the assessee’s contention that it was purely reimbursement received for Construction and Management...

TP Adjustment - ALP adjustment qua receipt of management services - the assessee has already filed its detailed paper book in the nature of supportive evidence...

TP Adjustment - secondment of employees by Assessee to its AE - the benchmarking done by the TPO by applying the same rate of thirty party placement agency is not...

TP Adjustment - receipt of management services from AEs - It is difficult to prove the services in terms of numbers but it can be seen only in ease of doing business in...

TP adjustment - intra-group services - Infrastructure consultancy and support charges - DR was unable to controvert the factual finding of the DRP that infrastructure...

Transfer pricing adjustments - Location Savings and Imputation of mark-up on pass through costs - this intra-group services rendered by the assessee to the parent...

The appellant availed CENVAT credit prior to registration. The department demanded interest on such credit, which was held impermissible as no demand for recovery of...

This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...

TP Adjustment - It is not the case that the assessee which is carrying on forwarding chain business has paid the management services for some other unrelated business...

Quick Updates: