Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights January 2020 Year 2020 This

TP Adjustment - interest free loan given to its associated ...


Interest-Free Loan Transfer Pricing Adjustment Overturned Due to Misapplication of Penal Interest Clause Comparisons.

January 21, 2020

Case Laws     Income Tax     AT

TP Adjustment - interest free loan given to its associated enterprise (AE) - Lower authorities have erred in going by the penal interest stipulation in the loan agreement to the corresponding interest benchmark in the overseas market. - Addition deleted.

View Source

 


 

You may also like:

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

  2. 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...

  3. 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...

  4. Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

  5. TP upward adjustment on account of interest free loan to AE - The interest cost compared to the amount of gross import of material and export generated by the taxpayer...

  6. TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

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

  8. 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...

  9. TP Adjustment - Notional interest - interest-free advances extended by the assessee to its AE - In an uncontrolled condition and between persons other than associated...

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

  11. Transfer pricing adjustment - interest free advances granted by the assessee to its Indian AE - base erosion theory - Tribunal rejected the the contention of the...

  12. Transfer pricing adjustment - the addition of ₹ 15.18 lac on account of interest on the deemed loan due to under-receipt of share premium cannot be sustained - AT

  13. Addition of interest attributable on the diversion of loan fund - Once own fund of the assessee exceeds the amount of interest free loans and advances, then a...

  14. 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) -...

  15. Deemed dividend u/s 2(22)(e) is not taxable in the hands of the assessee company if it is not a shareholder in the companies that extended loans. It is chargeable to tax...

 

Quick Updates:Latest Updates