Upward TP adjustment on account of corporate guarantee - There ...

Only the "Proper Officer" can assess corporate guarantee-related transfer pricing adjustments for imported goods. No other authority has this power.

December 6, 2021

Case Laws Income Tax AT

Upward TP adjustment on account of corporate guarantee - There has to be a proper determination as to whether there is prohibition of the imported goods. This exercise can be carried only by a “Proper Officer” and cannot be usurped by the third or fourth respondents or their counter parts in Chennai - Merely because the officers of the third and the fourth respondents have powers to investigate by itself means will not mean that they can insist on a “hands off approach” by a competent officer who have been given the powers to assess Bill of Entry filed by an importer. - AT

View Source

← Previous Next →

Upward TP adjustment on account of corporate guarantee - There ...

Only the "Proper Officer" can assess corporate guarantee-related transfer pricing adjustments for imported goods. No other authority has this power.

December 6, 2021

Case Laws Income Tax AT

You may also like:

The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The...

The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

HC determined that the Transfer Pricing Officer (TPO) must first evaluate whether a corporate guarantee constitutes an international transaction under Section 92B before...

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

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

The ITAT allowed the assessee's appeal for statistical purposes and remanded the matter to the Assessing Officer/Transfer Pricing Officer for fresh adjudication....

Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The...

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 on Corporate Guarantee Charges, Interest on Optionally Convertible Loans (OCL), and Reimbursement of Expenses. - The Tribunal found that...

TP Adjustment in respect of extension of performance/ corporate guarantee - Even if it is reckoned as international transaction, then also on FAR analysis and looking to...

Transfer pricing adjustment – Guarantee charges for guarantee to AE – no upward adjustment in the ALP in relation to charging of guarantee commission over and above...

The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

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)...

The Principal Commissioner or Commissioner having jurisdiction over transfer pricing matters has been empowered, effective April 1, 2022, to invoke revisionary action...

Quick Updates: