Home Highlights February 2021 Year 2021 This

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

3. 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...

4. 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...

5. TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned...

6. TP adjustment - Adjustment made by the TPO on the value of electricity supplied by the Captive Power Plant (CPP) to its manufacturing units by benchmarking the same with...

7. Transfer pricing adjustment - Risk adjustment and negative working capital adjustment - Though, it may be true, in case of a captive service provider AE takes all major...

8. 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...

9. 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...

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

11. 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...

12. 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...

13. Validity of Intimation passed u/s 143(1) - Rectification of arithmetical error or prima facie incorrect claim - CPC is entitled to make adjustments as per 1st proviso of...

14. The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP...

15. Disallowance of interest relating to Capital Work in Progress (CWIP) - The Appellant has furnished the relevant working capital facility agreements and ledger account to...