Transfer pricing adjustment - Early or late realization of sale ...

Transfer Pricing Adjustment for Sale Proceeds Timing Is Incidental, Not Separate; Interest on Delayed Proceeds Not International Transaction.

January 11, 2016

Case Laws Income Tax AT

Transfer pricing adjustment - Early or late realization of sale proceeds is only incidental to transaction of sale, but not a separate transaction in nature. - the impugned transaction of interest on delayed realization of sale proceeds is not international transaction - AT

View Source

← Previous Next →

Transfer pricing adjustment - Early or late realization of sale ...

Transfer Pricing Adjustment for Sale Proceeds Timing Is Incidental, Not Separate; Interest on Delayed Proceeds Not International Transaction.

January 11, 2016

Case Laws Income Tax AT

You may also like:

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

Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment...

Transfer pricing adjustment - Correspondent Banking Activities - The main business transactions have been accepted to be at arm’s length and hence, the ld. TPO cannot...

Transfer Pricing (T.P) adjustments - notional interest on receivables from Associated Enterprises (A.E) - the credit period extend by the assessee to its AE is very...

TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from...

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) -...

TPA - Addition in respect of ALP in respect of receivables due from AEs - Early or late realization of sale proceeds is only incidental to transaction of sale, but not a...

Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude...

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 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 - Adjustment on account of notional interest on the receivables - when the assessee is having their own funds and not paying interest on any...

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

TP Adjustment - Interest on extended credit to AE - assessee granted extended credit periods to non-AEs without charging any interest on delayed payments - CIT(A) has...

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...

Valuation - sale of Gypsum - mere bifurcation of the sale price of the goods in a mutual contract between the parties under a separate bargain or even a common bargain...

Quick Updates: