Home Highlights April 2016 Year 2016 This

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1. Computation of Profit Level Indicator (PLI), being, the Operating Profit/Total Cost (OP/TC) of the assessee -Like debts becoming bad from the sale of goods assuming the...

2. TP Adjustment - PLI computation - if rental expenditure is considered as an operating expenditure, then the reimbursement should be set off against the rental...

3. External Commercial Borrowings (ECB) Policy – Non-Banking Financial Company – Infrastructure Finance Companies (NBFC-IFCs) - Circular

4. TP Adjustment - ALP determination - depreciation - operating cost - since the assets are used by the assessee with respect to the services provided to AE and hence the...

5. Deemed dividend u/s 2(22)(e) is not taxable in the hands of the assessee company if it is not a shareholder in the companies that extended loans. It is chargeable to tax...

6. TP Adjustment - The main contention was whether forex losses should be considered as non-operating or operating for the purpose of computing the Profit Level Indicator...

7. Deduction u/s 80IA - whether assessee fulfilled the condition of sub-Section (4)(i)(b) of Section 80IA? - partnership firm was converted into a company - For the...

8. Adjustment towards foreign exchange fluctuation - non-consideration of impact of abnormal movement in the foreign exchange rates while computing the operating profit...

9. Foreign exchange gain/loss treated as non-operative for assessee and comparables due to risk mitigation by associated enterprises. Safe Harbor Rules not applicable as...

10. Disallowance u/s 36(1)(iii) - claim of interest expenditure - The companies GIL and CNIL are subsidiary companies, which clearly indicates that the investment made by...

11. TP adjustment - Inclusion of excise duty on the operating revenue for two comparables - By including excise duty in the case of two comparables by the ld. TPO, the...

12. Income from the nature of interest received by the assessee in DRDO/ISRO accounts (for short ‘FD A/cs’) - the assessee, DRDO/ISRO are either Government Departments or...

13. Additions as interest income - compensation received by the assessee - As the business of assessee was set up and had started and there was huge investment made by...

14. The case pertains to the disallowance of deduction claimed u/s 80IA by an assessee operating two units, one for paper manufacturing and another for power generation. The...

15. TP adjsutment - “AE” investment banking activities - comparable selection - The persistence loss- making company are normally excluded as comparable. As per the...