Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights October 2014 Year 2014 This

Transfer pricing adjustment – Computation of ALP – Advances made ...

Case Laws     Income Tax

October 18, 2014

Transfer pricing adjustment – Computation of ALP – Advances made to overseas subsidiaries – The differences are so fundamental that these differences, to use the phraseology employed in Rule 10 B (1)(a)(ii), “could materially affect the price in the open market“ - the application of LIBOR plus rate or, for that purpose, any bank rate will be inappropriate to this case. - AT

View Source

 


 

You may also like:

  1. TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

  2. TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

  3. TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...

  4. TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

  5. Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

  6. Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

  7. Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

  8. Transfer pricing adjustment – Guarantee charges for guarantee to AE – no upward adjustment in the ALP in relation to charging of guarantee commission over and above...

  9. TPA - This is a case in which transfer pricing provisions cannot be applied because the application of ALP adjustment will indeed result in erosion of Indian tax base-...

  10. Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

  11. Transfer pricing adjustment - advance to subsidiary - even though this interest rate could reach upto 400 basis points in some cases, there cannot be any good reason...

  12. Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

  13. TP Adjustment - MAM - Considering brokerage rate of all Non-AEs for the comparability purposes - Arm's Length Price (ALP) of broking commissions - The Tribunal directed...

  14. The Appellate Tribunal examined Transfer Pricing Adjustment disallowing cost of support services. The cost allocation key based on 'headcount' was accepted by the...

  15. TP adjustment - notional interest - short term advances made by the assessee to its associated enterprises - The assessee being unable to establish with evidence the...

 

Quick Updates:Latest Updates