Penalty u/s 271(1)(c) - addition on account of Transfer Pricing ...

No Penalty Imposed: Transfer Pricing Adjustments Deemed Debatable, All Related Disallowances and Additions Deleted u/s 271(1)(c.

August 16, 2021

Case Laws Income Tax AT

Penalty u/s 271(1)(c) - addition on account of Transfer Pricing adjustment relating to payment of commission - it is evident that these are debatable issues - In any case of the matter, while deciding the quantum appeals of the assessee and the revenue in the earlier part of the order, we have deleted all the disallowances/additions based on which penalty under section 271(1)(c) of the Act was imposed.- No penalty - AT

View Source

← Previous Next →

Penalty u/s 271(1)(c) - addition on account of Transfer Pricing ...

No Penalty Imposed: Transfer Pricing Adjustments Deemed Debatable, All Related Disallowances and Additions Deleted u/s 271(1)(c.

August 16, 2021

Case Laws Income Tax AT

You may also like:

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 case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

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

The ITAT, an Appellate Tribunal, considered the issue of penalty u/s 271G in a case involving Transfer Pricing (TP) adjustment. The assessee did not initially provide...

Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

Penalty u/s. 271(1)(c) - Transfer pricing adjustment - Debatable issue - Base Erosion Theory - Reading a particular paragraph of the observations of the AO’s order...

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

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

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

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

Quick Updates: