Navigating Through Reimbursement Expenses, DDT Refunds, and Transfer Pricing Adjustments

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... o various assessments from the Assessment Years (AY) 2010-11 to 2014-15, as detailed in the judgment of the Income Tax Appellate Tribunal, Ahmedabad​​. The focus is on the key legal issues raised, including the disallowance of reimbursement expenses, refund of excess Dividend Distribution Tax (DDT), the application of the Arm's Length Principle (ALP) in transfer pricing, and the as .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... he disallowance without a fair opportunity of hearing and without specific findings that the expenses were not incurred wholly for the business​​. 2. Refund of Excess Dividend Distribution Tax (DDT) Context and Controversy: The appellant sought refunds of excess DDT paid on dividends distributed to a German shareholder, arguing that the CIT(A) failed to direct the AO to g .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... oyalty was paid to associated enterprises based on net sales for technical support and assistance, and Management Fees were paid to Schaeffler Holding (China) Co. Limited​​. Legal Analysis: The key question was whether TNMM or CUP was the most appropriate method for determining the ALP. The CUP method compares direct prices, while TNMM compares net profit margins. The ITA .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X