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 October 2018 Year 2018 This

TPA - receivables forming a part of international transaction - ...


Receivables Over 180 Days Not Automatically International Transactions, Says TPO Decision Lacks Justification.

October 23, 2018

Case Laws     Income Tax     AT

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

View Source

 


 

You may also like:

  1. Outstanding receivables from AEs exceeding agreed credit period constitutes separate international transaction of providing capital financing/lending receivables, not...

  2. The ITAT held that the TPO erred in deeming international transactions and determining arm's length price (ALP) for the period after cessation/expiry of the service...

  3. The ITAT Hyderabad addressed a Transfer Pricing (TP) Adjustment issue regarding interest on outstanding receivables, determining if it constitutes an international...

  4. Regarding the scope of Section 92BA(i) as omitted, the Tribunal held that the reference made to the Transfer Pricing Officer (TPO) for the specified domestic transaction...

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

  6. TP Adjustment - international transactions u/s. 92B or not - In absence on any such agreement, the first and primary condition of holding the transaction in question as...

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

  8. Reopening of assessment u/s 147 - Tribunal was correct to hold that when reference was made to the TPO by AO for determination of arm’s length price in relation to the...

  9. Determination of transaction - statutory change to section 92CA - AO is now bound by the order of the TPO on the computation of the arm’s length price of an...

  10. ITAT addressed multiple transfer pricing issues in an international business case. TPO was directed to reassess arm's-length pricing for trading segment transactions,...

  11. TP Adjustment - Interest on delayed receivables - The ITAT found that the conditions laid down by previous rulings, specifically in the case of PCIT vs. Kusum...

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

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

  14. TP adjustment - international transaction - expenses - incurred wholly and exclusively for the purpose of business or not - In the present case, the AO, by applying...

  15. TP adjustment on account of back-to-back counter bank guarantee - TPO, by considering the rate charged by Bank of Baroda for issuance of guarantee against 100% counter...

 

Quick Updates:Latest Updates