There is no dispute that the assessee has under priced its ...

Assessee's Self-Adjustment in Transfer Pricing Not Eligible for Section 10B Deduction, Says Tax Authority.

July 4, 2015

Case Laws Income Tax AT

There is no dispute that the assessee has under priced its services to AE’s and therefore made transfer pricing adjustment suo moto. This peculiar conduct of the assessee, if allowed to claim deduction u/s 10B of the Act will go against the legislative intention. - AT

View Source

← Previous Next →

There is no dispute that the assessee has under priced its ...

Assessee's Self-Adjustment in Transfer Pricing Not Eligible for Section 10B Deduction, Says Tax Authority.

July 4, 2015

Case Laws Income Tax AT

You may also like:

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) -...

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

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

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...

Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections...

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

The ITAT allowed the assessee's appeal regarding transfer pricing adjustments for power supply, ruling that the assessee's method for determining arm's length price was...

This case deals with transfer pricing adjustments made by the tax authorities regarding international transactions involving sale of Paclitaxel, Disodium Pamidronate,...

TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned...

Interest u/s 234 B - Advance tax - Adjustment / Credit for cash as seized - there is no prohibition to adjust the seized cash with self assessment tax. What is...

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

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

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...

The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

Quick Updates: