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 July 2020 Year 2020 This

TP Adjustment - working capital adjustment - No document whereby ...

Case Laws     Income Tax

July 27, 2020

TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned dispute resolution panel with respect to granting of working capital adjustment. Even in the transfer pricing study report it could not be shown that assessee himself has claimed any working capital adjustment while preparing its comparability analysis - Additions confirmed - AT

View Source

 


 

You may also like:

  1. TP Adjustment - Working capital adjustment - there is no need for making any negative working capital adjustment, when assessee does not carry on with any working...

  2. TP Adjustment - No adjustment towards working capital has been allowed to the assessee - One has to see that reasonable adjustment is being made so as to bring both...

  3. TP Adjustment - Working capital adjustment - Making a working capital adjustment is an attempt to adjust for the differences in time value of money between the tested...

  4. TP Adjustment - Grant of negative working capital adjustment - Since the assessee does not have any working capital risk, the question of negative working capital does...

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

  6. TP Adjustment - Working capital adjustment for computing the margin of the comparables - in keeping with the OECD guidelines, endeavor should be made to bring in...

  7. TP Adjustment - Adjustment on account of working capital adjustment - Guidance on comparability adjustments is found in paragraphs 3.47-3.54 and in the Annexure to...

  8. TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...

  9. TP adjustment - notional interest - short term advances made by the assessee to its associated enterprises - The assessee being unable to establish with evidence the...

  10. TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of...

  11. TP Adjustment - CIT(A) under the garb of "rule of consistency" adopted the TP analysis made by the TPO - This method of TP analysis is unheard of as every assessment...

  12. TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result...

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

  14. This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

  15. 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:Latest Updates