TP Adjustment - interest on debentures invested in the ...

Transfer Pricing Adjustment on Interest Under India-Mauritius Tax Treaty Deemed Unsustainable Due to No Actual Interest Income Received.

November 23, 2019

Case Laws Income Tax AT

TP Adjustment - interest on debentures invested in the Associated Enterprise (AE) - India–Mauritius tax treaty - the addition made on account of transfer pricing adjustment is unsustainable as the assessee has actually not received any interest income.

View Source

← Previous Next →

TP Adjustment - interest on debentures invested in the ...

Transfer Pricing Adjustment on Interest Under India-Mauritius Tax Treaty Deemed Unsustainable Due to No Actual Interest Income Received.

November 23, 2019

Case Laws Income Tax AT

You may also like:

Assessee employed by Indian entity but sent on long-term international assignment to Singapore. Salary received in India for administrative reasons, but employment...

Chargeability to capital gains tax in India - Applicant, a tax resident of Mauritius - transfer of 9,870,912 shares of an Indian Company - applicant is not chargeable to...

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

Deemed dividend addition u/s 2(22)(e) - India-Mauritius Tax Treaty - the applicable rate of tax is 5% as correctly canvassed by assessee.

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

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

Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude...

TP Adjustment - Interest on extended credit to AE - assessee granted extended credit periods to non-AEs without charging any interest on delayed payments - CIT(A) has...

Income accrued in India - Permanent Establishment (PE) in India under Article–5 of the India–Mauritius Tax Treaty - The two companies were not exclusively working for...

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 company was denied exemption under Article 13(3B) and 13(4) of the India-Mauritius Treaty, and its capital gains from sale of shares, futures, and options...

Income deemed to accrue or arise in India - addition on account of LTCG to be taxed u/s 112 - Scope of holding Tax Residency Certificate of Mauritius (TRC) - The...

Income accrued in India - For the purpose of applying Article 13(5) of the India-Belgium tax treaty two fold conditions are required to be cumulatively satisfied viz....

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...

Transfer Pricing Adjustment - Adjustment on account of notional interest on the receivables - when the assessee is having their own funds and not paying interest on any...

Quick Updates: