Deduction u/s 10A on suo moto transfer pricing adjustment made ...

Case Laws Income Tax

June 24, 2019

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 amount of voluntary TP adjustment made by the assessee.

View Source

← Previous Next →

Deduction u/s 10A on suo moto transfer pricing adjustment made ...

Case Laws Income Tax

June 24, 2019

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) -...

The assessee is entitled to claim deduction u/s 10A/ u/s 10AA on additional income offered on account of suo moto adjustment and transfer pricing provisions.

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...

There is no dispute that the assessee has under priced its services to AE’s and therefore made transfer pricing adjustment suo moto. This peculiar conduct of the...

Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment...

TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for...

Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

Disallowance u/s 14A read with Rule 8D - Assessing Officer did not record objective satisfaction for not accepting suo moto disallowance made by assessee. ITAT directed...

Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) Adjustment where the Transfer Pricing Officer (TPO) determined the Arm's Length Price...

Quick Updates: