Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights April 2017 Year 2017 This

TPA - Addition in respect of ALP in respect of receivables due ...

Case Laws     Income Tax

April 11, 2017

TPA - Addition in respect of ALP in respect of receivables due from AEs - Early or late realization of sale proceeds is only incidental to transaction of sale, but not a "separate transaction in nature. The impugned transaction of interest on delayed realization of sale proceeds is not international transaction - AT

View Source

 


 

You may also like:

  1. TP Adjustment - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of...

  2. TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

  3. Transfer Pricing - adjustment to ALP - addition - consideration of transactions both with AEs and Non-AEs for the purpose of recommending adjustment - AT

  4. TPA - ALP - interest on delayed realization of receivables is a separate international transaction and, therefore, requires separate benchmarking. It has nothing to do...

  5. TPA - receivables forming a part of international transaction - TPO is not justified in concluding that the figure of receivables beyond 180 days constitutes an...

  6. 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,...

  7. Transfer pricing adjustment - Interest on delayed debtors/outstanding receivables from the AE - the assessee is fallowing a consistency approach of equality by not...

  8. Transfer pricing adjustment - Early or late realization of sale proceeds is only incidental to transaction of sale, but not a separate transaction in nature. - the...

  9. TP Adjustment - interest on outstanding receivables - The realization of invoices were made with abnormal delay. This, in our considered opinion, tantamount to indirect...

  10. Penalty u/s 271(1)(c) for furnishing inaccurate particulars of income - adjustment made u/s 92CA - penalty levied u/s 271(1)(c) on the adjustment made u/s 92CA is not...

  11. TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

  12. TP adjustment for corporate guarantee commission at 0.50% on guaranteed amount directed. Interest on receivables beyond agreed credit period of 60-240 days for non-AEs...

  13. TP Adjustment - Interest on delayed receivables - only two instances where there has been a marginal delay of 60 days and 26 days. Considering the nominal delay in the...

  14. TP Adjustment - interest on delayed receivables - Assessee pleaded that the deferred receivables do not constitute a separate international transaction requiring...

  15. TP Adjustment - Determination of ALP - electricity supply bites captive power generation plant to its AEs - the assessee is justified in adopting the ALP of the...

 

Quick Updates:Latest Updates