Transfer pricing adjustment (TPA) - ALP determination - the ...

Contract Termination Fees Must Be Treated as Operating Revenue for Transfer Pricing Adjustments in International Transactions.

March 2, 2017

Case Laws Income Tax AT

Transfer pricing adjustment (TPA) - ALP determination - the contract termination fee also partakes the character of the contract receipt and is to be treated as operating revenue of the international transactions more particularly since the expenses incurred by the assessee on such contract has been taken as operating cost. - AT

View Source

← Previous Next →

Transfer pricing adjustment (TPA) - ALP determination - the ...

Contract Termination Fees Must Be Treated as Operating Revenue for Transfer Pricing Adjustments in International Transactions.

March 2, 2017

Case Laws Income Tax AT

You may also like:

Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

Characterization of receipt - Compensation receipt on termination of contract - Addition under Section 28(ii)(e) - The Tribunal differentiates between termination and...

Termination of contract - non-performance of the contract - the termination of the contract was illegal and without following due procedure as required under the...

Capital expenditure vs Revenue expenditure - expenditure on payment of lease rent and maintenance of the pipeline as per Build, Own, Operate, Transfer (BOOT) contract -...

Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated...

Termination fee - demand of service tax under the category of “permitting commercial use or exploitation of any event service” - The tripartite agreement which has been...

ITAT adjudicated transfer pricing dispute regarding comparable company selection. The tribunal determined the Arm's Length Price (ALP) computation by the Transfer...

The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The...

ITAT adjudicated a dispute regarding the nature of receipt of membership and share transfer fees. The tribunal examined whether these one-time fees constitute capital or...

Transfer pricing adjustment for comparable selection was challenged due to functional dissimilarity. The assessee provided IT-enabled services and back-end credit card...

CIRP - Liability to pay transfer fee of 10% of the prevailing market value of the Kharagpur land - The court determines the validity of notices issued by the respondents...

ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely...

Genuineness of sale price of shares - transfer of same share at different price - a much higher price in the hands of Empee Sugars & Chemicals Ltd., was undoubtedly to...

Transfer pricing adjustment - in arriving at the operating cost in transfer pricing matters the principles of Cost Accounting will not be strictly applicable where cost...

Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

Quick Updates: