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1. TP Adjustment - ALP adjustment qua receipt of management services - the assessee has already filed its detailed paper book in the nature of supportive evidence...

2. Corporate Guarantee or Letter of Comfort given by the assessee to its Associate Enterprise does not involve any cost to the assessee, therefore, it was outside the ambit...

3. Royalty receipts were subject to transfer pricing adjustment by TPO on basis of differences in amounts reflected in Form 3CEB of assessee vis-à-vis its group entities,...

4. The ITAT Mumbai held that the Transfer Pricing Officer (TPO) unjustifiably rejected the benchmarking analysis done by the assessee for determining the Arm's Length Price...

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

6. TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

7. TDS u/s 195 - commission paid outside India - disallowance made under Section 40(a)(i) - the Associated Enterprises has rendered services out of India in the form of...

8. TPA - This is a case in which transfer pricing provisions cannot be applied because the application of ALP adjustment will indeed result in erosion of Indian tax base-...

9. Existence of Fixed Place Permanent Establishment (“Fixed Place PE”) and Supervisory Permanent Establishment (“Supervisory PE”) - India-Japan DTAA - Merely providing...

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

11. TP adjustment - Benchmarking of interest on interest free advances good to the subsidiary companies - In the present case, the cost borrowing of the assessee does not...

12. The assessee provided project advisory services to Special Purpose Vehicles (SPVs) formed to execute infrastructure contracts obtained from NHAI. The assessee contended...

13. TDS u/s 195 - Disallowance of commission u/s 40(a)(ia) - the commission has been paid to various nonresident entities in respect of sales affected by the assessee...

14. Penalty u/s 271G - assessee applied TNMM for determining of ALP - information/documents sought for determining of ALP as per CUP method - the difficulty in maintaining...

15. TP adjustment on account of payment of overseas support fee - The assessee has its head office outside India and the decision, on the basis of which the assessee gets...