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 May 2022 Year 2022 This

TP Adjustment - amount disallowed by the AO, viz., Product ...

Case Laws     Income Tax

May 7, 2022

TP Adjustment - amount disallowed by the AO, viz., Product development expenses, provision for customer claims should be excluded from the cost while computing margin of the assessee - Net margins of the assessee as well as comparable companies are computed under TNM method on the basis of book results without making any adjustment as prescribed in sec.28 to 44 of the Act (both in the hands of the assessee as well as in the hands of comparable companies.) Hence these contentions of the assessee are untenable and hence liable to be rejected. - AT

View Source

 


 

You may also like:

  1. Various issues related to allowability of expenses, deductions, transfer pricing adjustments, and other income tax matters for a pharmaceutical company. Key points are:...

  2. TP Adjustment - AMP expenses by applying bright line test on protective basis - TP adjustment amounting by applying BLT is not sustainable on protective basis having no...

  3. TP Adjustment - apportioning the expenses of assessee’s affiliates - Also noted that the assessee has received certain services from its AE which has been treated by the...

  4. TP adjustment of interest - CIT(A) confirmed upward adjustment towards interest by adopting rupee loan rate instead of LIBOR linked rate in respect of foreign currency...

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

  6. Upward TP adjustment on account of reimbursement of expenses - The expenses in question were thus clearly for the purpose of the business of the assessee, and deserved...

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

  8. Disallowance of various expenses on ad hoc basis - While scrutinizing the expenditure if the expenses claimed are not having any nexus to the business of the assessee or...

  9. TPA - ALP - Provision of expenses - The AO has misunderstood the provision debited and credited to the price support account as a mere provision and not as an actual...

  10. The assessee bank made provisions for group gratuity and leave encashment by debiting expenses in its books, but these provisions were never treated as real expenses for...

  11. Computation of deduction u/ss 80IB/80IC and 10B - AO allocated Head Office expenses to eligible units, reducing deduction. Tribunal consistently restores issue with...

  12. TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

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

  14. TP adjustment - specified domestic transactions (SDT) - The ITAT held that since the provision (Section 92BA(i)) was omitted without a saving clause effective from...

  15. TP Adjustment - the TPO is erred in adopting CUP method for few transactions when he has accepted overwhelming majority of transactions under TNMM method. The DRP...

 

Quick Updates:Latest Updates