Home Highlights January 2016 Year 2016 This

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1. 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) -...

2. MAT - AO add back the Income-tax paid in Spain while computing book profit u/s. 115JB - only taxes specified in Explanation 2 can be added back while computing book...

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

4. Addition u/s 14A r.w.r. 8D - Addition under special provision u/s 115JB - Minimum Alternate Tax (MAT) - the case revolved around the disallowance made under Section 14A...

5. MAT computation u/s 115JB - Adjustment of resultant gains / losses of the amalgamation - Accumulated loss - cancellation of shares - Share Capital was reduced with a...

6. TP Adjustments - AO does not have the jurisdiction to propose any transfer pricing adjustment in case where he has not made any reference to the TPO. Therefore the...

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

8. TP Adjustment - Addition of international transaction related to the demerger - The High court identified a jurisdictional overreach by the AO, who made an adjustment...

9. MAT computation u/s 115JB - Action of AO including the agriculture income for the purpose of MAT is not correct - Firstly, there was no mistake in the original orders...

10. 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...

11. MAT is paid, additions were made to regular income, penalty not levied – 115JB, 271(1)(c)

12. MAT computation - adjustment of rent/lease equalization reserve u/s 115JB of the Act - The Assessee contended that the reserve was not covered under Explanation 1(b) or...

13. MAT - Adjustments to book profit - Disallowance as per the clause (f) to Explanation-1 of Sec. 115JB of the Act independently - there is no mechanism provided under the...

14. 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...

15. Computation of MAT u/s 115JB - Addition towards delayed payment of gratuity and leave encashment - in computation of book profit only provision for unascertained...