Home Highlights April 2016 Year 2016 This

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1. Levy of late filing fees u/s 234E - TDS returns - adjustment in respect of levy of fees under section 234E was indeed beyond the scope of permissible adjustments...

2. Levy of fees u/s 234E - TDS return - adjustment in respect of levy of fees under section 234E was indeed beyond the scope of permissible adjustments contemplated u/s 200A. - AT

3. Levy of fees under section 234E - adjustment in respect of levy of fees under section 234E was indeed beyond the scope of permissible adjustments contemplated under...

4. TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result...

5. Adjustment of excess amount of service tax paid - Scope of the term subsequent period

6. 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...

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

8. Validity of intimation / adjustment u/s 143(1) - Exemption u/s 11A denied - Registration no. u/s 12AA was not mentioned in the ITR - Since the adjustment made by the AO...

9. TP Adjustment - upward adjustment under the provisions of section 92 - ALP determination - The amount of depreciation claimed by the assessee in the ratio of turnover...

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

11. TP adjustment - Determining the Arm's Length Price of international transactions in respect of "advisory services" - we adopt judicial consistency in the absence of any...

12. TP adjustment in Distribution activity, described as ESAS - ALP and the consequential transfer pricing adjustment are contemplated only in respect of the international...

13. Levy of late fee u/s 234E - delay in delivering the quarterly TDS statement as well as TDS return - Once the amendment is held to be prospective, the AO gets the...

14. TP adjustment - upward adjustment in imputing notional interest on the outstanding overdue receivables from Associated Enterprises - working capital adjustments on the...

15. TP Adjustment - No adjustment towards working capital has been allowed to the assessee - One has to see that reasonable adjustment is being made so as to bring both...