Transfer pricing adjustment - interest free advances granted by ...

July 19, 2016

Case Laws Income Tax AT

Transfer pricing adjustment - interest free advances granted by the assessee to its Indian AE - base erosion theory - Tribunal rejected the the contention of the assessee that, in principle, no arm’s length price adjustments can be made in respect of the interest free advances granted by the assessee to its Indian AE, i.e. Datex Ohmeda India Pvt Ltd. - AT

View Source

← Previous Next →

Transfer pricing adjustment - interest free advances granted by ...

July 19, 2016

Case Laws Income Tax AT

You may also like:

Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

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...

TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

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

TP upward adjustment on account of interest free loan to AE - The interest cost compared to the amount of gross import of material and export generated by the taxpayer...

TP adjustment - notional interest - short term advances made by the assessee to its associated enterprises - The assessee being unable to establish with evidence the...

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...

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...

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 officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

TP Adjustment - arm’s length price of interest on short term loan granted to the AE - The fact that the assessee has provided a short term loan only for a period of 15...

The assessee failed to demonstrate that the financial assistance availed on interest was utilized for business purposes without diversion. Where an assessee has...

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

Transfer pricing adjustment - No interest having been charged by the assessee to the non-AE outstandings, its transaction of outstanding receivables with AE without...

TP Adjustment - Notional interest - interest-free advances extended by the assessee to its AE - In an uncontrolled condition and between persons other than associated...

Quick Updates: