TP adjustment - Enhanced deduction u/s.10A - as per Section ...

TP Adjustments Must Be Separate for Enhanced Deductions u/s 10A, Cannot Be Combined with Other Additions.

February 8, 2019

Case Laws Income Tax AT

TP adjustment - Enhanced deduction u/s.10A - as per Section 92C(4) of the Act, TP addition has to be separately done, whatever may be the addition in respect of other aspects but that cannot be brought together with TP adjustment or addition - it does not qualify for enhanced deduction u/s.10A.

View Source

← Previous Next →

TP adjustment - Enhanced deduction u/s.10A - as per Section ...

TP Adjustments Must Be Separate for Enhanced Deductions u/s 10A, Cannot Be Combined with Other Additions.

February 8, 2019

Case Laws Income Tax AT

You may also like:

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) -...

Disallowance of expenses on non-deduction of tax - Without going into the merit of the addition, we find the alternate argument of the ld. Counsel for the assessee...

Revision u/s 263 by CIT - Regarding the claim of the revenue that, no deduction is allowable u/s 92C(4) of the Act - The claim under Section 10A is not enhanced on...

Deduction u/s 10A on suo moto transfer pricing adjustment made by the assessee - AO directed to delete this disallowance and grant benefit of deduction u/s 10A on the...

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 - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...

The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP...

Deduction u/s 80IA on the enhanced expenditures made to sub-contractors - The issue of the claim of higher deduction on the enhanced profits has been a contentious one....

The Appellate Tribunal ruled in favor of the assessee on the following issues: TP adjustment on international transactions for sale of goods, disallowance u/s 14A read...

Deduction u/s 10A - the deduction under s. 10A is not an exemption but only a deduction under Chapter III of the IT Act and the provisions of s. 80AB of Chapter VI-A...

Disallowance of deduction claimed u/s 10AA after claiming deduction / exemption u/s 10A - SEZ unit - As on the commencement of assessment year 2006-07, which is the...

TP adjustment - upward adjustment in imputing notional interest on the outstanding overdue receivables from Associated Enterprises - working capital adjustments on the...

TP Adjustment - ALP determination qua domestic transactions entered into by the assessee with its partner u/s 92BA(i) of the Act - no addition on account of TP...

TP Adjustment - apportioning the expenses of assessee’s affiliates - Also noted that the assessee has received certain services from its AE which has been treated by the...

Computing the deduction u/s 10A - addition made on account of the disallowance of the provident fund/ ESIC payments u/s 36(v) r.w.s 2(24) (x) - The contention of the...

Quick Updates: