TPO and DRP have committed a fallacy, firstly, by considering ...

Case Laws Income Tax

May 18, 2016

TPO and DRP have committed a fallacy, firstly, by considering the AE as a “tested party” and secondly, relying upon USD Corporate Bond Rates to benchmark the ALP of the interest rate because the interest rates for bonds or loan has to be seen from the point of view of borrowers creditworthiness and not the lender’s creditworthiness. - AT

View Source

← Previous Next →

TPO and DRP have committed a fallacy, firstly, by considering ...

Case Laws Income Tax

May 18, 2016

You may also like:

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 - Rejection of Associated Enterprises as the tested party - foreign Associated Enterprises satisfied all the criteria for being taken as a tested party....

TP adjustment - onsite development and project coordination fee’ - Associated enterprise can be considered as a tested party, in the present case. Accordingly, we direct...

TP Adjustment - TDS deducted on interest paid to AE on External Commercial Borrowings - procedure followed by the assessee for grossing up of interest is contrary to...

TP adjustment made in respect of provision of back office services - In any case, we find the main grievance of the ld. DRP seems to be that AE revenue is only ₹...

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)...

The dispute centered around the classification of imported goods, calcium carbonate, under the appropriate Customs Tariff Heading (CTH). The revenue classified it as...

TP Adjustment - determination of Arm's Length Price - intra group services transactions as Cross-charges - Documents submitted by the assessee do not conclusively...

TP adjustment - tested party - As per Guidance Note on report u/s 92E and transfer pricing guidelines issued by the OECD and united nation practical manual of transfer...

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...

TP Adjustment - International transactions with its AEs for providing software consultancy services - Selection of MAM - DRP without appreciating the above facts, has...

TP Adjustment - intra group services - The assessee has failed to completely demonstrate the Arm’s Length Price of intra group services by satisfying need test, benefit...

TP Adjustment - arm’s length price (ALP) of the international transaction - The tinkering of PLI by substituting the denominator with total cost is unacceptable...

Forum for Arbitration - Seat of the arbitral proceedings - The closest connection test strongly relied upon by Mr. Himani would only apply if it is unclear that a seat...

Valuation - special inspection charges or special testing charges incurred - third party inspection - the appellant is not obliged to get this special testing and...

Quick Updates: