TP Adjustments - Arm’s Length adjustment in respect of ...

Case Laws Income Tax

March 30, 2020

TP Adjustments - Arm’s Length adjustment in respect of outstanding receivables - the assessee is a debt free company as is reflected in the profit and loss account - re-characterisation of the outstanding receivables as loan is impermissible unless the transactions are found to be substantially at variance with the stated form.

View Source

← Previous Next →

TP Adjustments - Arm’s Length adjustment in respect of ...

Case Laws Income Tax

March 30, 2020

You may also like:

TP adjustment - Determining the Arm's Length Price of international transactions in respect of "advisory services" - we adopt judicial consistency in the absence of any...

Transfer pricing adjustment - No interest having been charged by the assessee to the non-AE outstandings, its transaction of outstanding receivables with AE without...

TP Adjustment - no merit in the adjustment made by the TPO/AO on account of outstanding receivables in respect of transaction pertaining to provision of IT and IT...

TP Adjustment - apportioning the expenses of assessee’s affiliates - Also noted that the assessee has received certain services from its AE which has been treated by the...

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

TP adjustment - upward adjustment in imputing notional interest on the outstanding overdue receivables from Associated Enterprises - working capital adjustments on the...

TP Adjustment - arm’s length price of interest on short term loan granted to the AE - The fact that the assessee has provided a short term loan only for a period of 15...

TP Adjustment - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of...

TP Adjustment with respect to receivables from the Associated Enterprises (AE) - With the Assessee having already factored in the impact of the receivables on the...

TP Adjustment - adjustment regarding outstanding receivables - company has a margin of 23.3% on Software Development segment as compared to 11.42% of the comparable...

TP Adjustment - upward adjustment under the provisions of section 92 - ALP determination - The amount of depreciation claimed by the assessee in the ratio of turnover...

TP Adjustment - Arm's Length Price (ALP) adjustment - The gross margins of assessee are much more than the gross margins of comparable companies chosen by the ld. TPO....

TP Adjustment - where the Tribunal has accepted the international transaction to be at Arm’s Length Price in the hands of AE, then the international transaction that the...

TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

TP adjustment - benchmarking of international transaction of import of raw materials - the TP adjustments in respect of this transaction should be restricted in terms of...

Quick Updates: