TP Adjustment - ALP - transaction on corporate guarantee - When ...

Case Laws Income Tax

November 8, 2019

TP Adjustment - ALP - transaction on corporate guarantee - When the guarantee has been given by two concerns and on similar terms and conditions arising out of the same transaction, two different and contradictory stands cannot be taken by the Revenue

View Source

← Previous Next →

TP Adjustment - ALP - transaction on corporate guarantee - When ...

Case Laws Income Tax

November 8, 2019

You may also like:

TP Adjustment - corporate guarantee given by the assessee company to its AEs - the corporate guarantee commission is an international transaction and should be charged @...

TP adjustment commission on letter of credit - international transaction or not? - CIT (A) appreciated the difference between corporate guarantee and Letter of Comfort....

TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the...

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...

TP Adjustment in respect of extension of performance/ corporate guarantee - Even if it is reckoned as international transaction, then also on FAR analysis and looking to...

TP Adjustment - Issuance of the corporate guarantee in favor of subsidiary - To be treated as a shareholders' activity or not - non-charging of corporate guarantee...

TP Adjustment - Arm's length price of the corporate guarantee fee - Lower authorities have also included a letter of comfort as part of corporate guarantee - We reject...

TP Adjustment - determination of arm’s length price, ALP - Transactions with the local vendors the terms of which are not influenced by Comer SpA cannot be treated as...

Transfer pricing addition on account of Corporate guarantee - performance guarantees in the instant case are a specie of the genus of corporate guarantee and cannot be...

TP Adjustment - TP Adjustment on corporate guarantee - As it is a case of holding company and subsidiary company transaction, we do not think any reason to consider 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 in Distribution activity, described as ESAS - ALP and the consequential transfer pricing adjustment are contemplated only in respect of the international...

TP Adjustment - adhoc adjustment - duty of the TPO is restricted only to the determination of the ALP of an international transaction between two related parties by...

Preferential transactions or not - Corporate Guarantees - the transaction covered under the Corporate Guarantees would not come within the parameters of the preferential...

Transfer pricing adjustment – Guarantee charges for guarantee to AE – no upward adjustment in the ALP in relation to charging of guarantee commission over and above...

Quick Updates: