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1. Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

2. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

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

4. The Tribunal held that the onus was on the Revenue to demonstrate the Appellant's default leading to inordinate delay in allotment of shares, which the Revenue failed to...

5. TP adjustment of interest - CIT(A) confirmed upward adjustment towards interest by adopting rupee loan rate instead of LIBOR linked rate in respect of foreign currency...

6. 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)...

7. Advance Against Depreciation - MAT u/s 115JB - AAD is income received in advance - the amount did not enter the stream of income - clause (b) of the Explanation 1 is not...

8. Book adjustments u/s 115JB - Insurance company - Minimum alternate tax (MAT) - these companies cannot be treated differently for the purpose of sec. 115JB - provisions...

9. TP adjustment on account of back-to-back counter bank guarantee - TPO, by considering the rate charged by Bank of Baroda for issuance of guarantee against 100% counter...

10. Assessment proceedings examined assessee's claim relating to ICDS adjustment made in intimation u/s 143(1). AO issued notices seeking information, assessee provided...

11. Rectification of mistake u/s 154 - non- inclusion of surrendered income in the Book Profits of the assessee as per section 115JB - the non- inclusion of surrendered...

12. 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...

13. TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

14. Adjustment made u/s 115JB in Rectification order u/s 154 - Debatable issue - addition of surrendered income by the assessee was included in the book profit of the...

15. MAT - Exempted income - adjustment to book profit u/s 115JB - there is no mechanism provided under the clause (f) to Explanation-1 of Sec. 115JB of the Act to make the...