Revision u/s 263 by CIT - Regarding the claim of the revenue ...

CIT Revises Order: No Deduction u/s 92C(4) for Assessee's Claim u/s 10A Due to Transfer Pricing Adjustments.

April 1, 2022

Case Laws Income Tax AT

Revision u/s 263 by CIT - Regarding the claim of the revenue that, no deduction is allowable u/s 92C(4) of the Act - The claim under Section 10A is not enhanced on account of transfer pricing addition and since the Assessee is not claimed deduction u/s 10A on enhanced assessed income and therefore the proviso to Section 92C(4) shall not apply. - AT

View Source

← Previous Next →

Revision u/s 263 by CIT - Regarding the claim of the revenue ...

CIT Revises Order: No Deduction u/s 92C(4) for Assessee's Claim u/s 10A Due to Transfer Pricing Adjustments.

April 1, 2022

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) -...

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

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

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

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...

Penalty u/s 271(1)(c) for furnishing inaccurate particulars of income - adjustment made u/s 92CA - penalty levied u/s 271(1)(c) on the adjustment made u/s 92CA is not...

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

The assessee is entitled to claim deduction u/s 10A/ u/s 10AA on additional income offered on account of suo moto adjustment and transfer pricing provisions.

Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections...

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...

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

TP adjustment - Enhanced deduction u/s.10A - as per Section 92C(4) of the Act, TP addition has to be separately done, whatever may be the addition in respect of other...

The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) Adjustment where the Transfer Pricing Officer (TPO) determined the Arm's Length Price...

Quick Updates: