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

Tax Authorities Must Maintain Consistency in Transfer Pricing for Corporate Guarantees under Similar Terms and Conditions.

November 8, 2019

Case Laws Income Tax AT

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 ...

Tax Authorities Must Maintain Consistency in Transfer Pricing for Corporate Guarantees under Similar Terms and Conditions.

November 8, 2019

Case Laws Income Tax AT

You may also like:

Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated...

The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The...

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...

HC determined that the Transfer Pricing Officer (TPO) must first evaluate whether a corporate guarantee constitutes an international transaction under Section 92B before...

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...

Invocation of performance guarantee - CIRP proceedings - the Adjudicating Authority passed the Order that “the performance guarantee given by the bankers on behalf of...

Transfer pricing - the issuance of corporate guarantees is covered by the residuary clause of the definition under section 92B of the Act but since such issuance of...

Demand of service tax - providing services without consideration (free) to its associate companies - activity of giving corporate guarantee - The Show Cause Notice...

IBC - Invoking Bank Guarantee - Corporate Debtor has issued bank guarantee for ensuring the price of goods. The bank guarantee is irrevocable and unconditional and...

The case involved a dispute regarding the applicability of service tax on corporate guarantee fees u/s 65(12)(a)(ix) of the Finance Act. The tribunal held that providing...

The ITAT addressed multiple transfer pricing issues regarding an assessee's international transactions. On the KPO versus software developer classification dispute, ITAT...

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...

Levy of Service tax - corporate guarantee - The appellant having received consideration against providing guarantee to its related company in the form of ‘corporate...

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

The Appellate Tribunal examined Transfer Pricing Adjustment disallowing cost of support services. The cost allocation key based on 'headcount' was accepted by the...

Quick Updates: