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 - Engineering services and Administrative Support ...


TPO's Rejection of Segmental Approach Overturned; Expenses for Outbound Engineering Services Deemed Commercially Justified.

May 31, 2022

Case Laws     Income Tax     AT

TP Adjustment - Engineering services and Administrative Support services - TPO has rejected the segmental approach adopted by the assessee for benchmarking its international transactions pertaining to provision of outbound engineering services - There is absolutely no doubt that the impugned expenditure has been incurred for the purposes of assessee’s business carried on by the assessee and that it was commercially expedient as well. - Addition deleted - AT

View Source

 


 

You may also like:

  1. TP Adjustment - Design Engineering Services - in the TP study report assessee applied margins at the entity level - it cannot be precluded from furnishing segmental...

  2. TP Adjustment - Recovery of expenses represent expenses incurred by the assessee company on behalf of AE towards Bid bond expenses. These expenses were also recovered by...

  3. ITAT affirmed weighted deduction eligibility u/s 35(2AB) for in-house scientific research expenditure. While R&D expenses incurred within India qualify for weighted...

  4. Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

  5. TP Adjustment - risk based assessment and selection of comparable - The glaring fallacy in the approach of the TPO lies on the fact that he has adopted FOB cost of goods...

  6. TP Adjustment - ALP determination - interest received on outbound loans - LIBOR v/s PLR - the prevailing LIBOR rate should be adopted for the interest received on...

  7. Rejection of Resolution Plan -Rejection of Resolution Plan -Rejection of Resolution Plan -Rejection of Resolution Plan -Rejection of Resolution Plan -Rejection of...

  8. Disallowance of conveyance expenses, staff welfare expenses, sundry expenses and traveling expenses - certain expenses were not supported by third party vouchers,...

  9. 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...

  10. Prior period expenses - It is not the case of the revenue that the expenses have been claimed twice but the short ground of disallowance is that since the expenses...

  11. Research and Development expenses (R&D Expenses) - Allowability of expenses u/s 35(2) - The expenses are not covered u/s 35(2) - The assessee has not claimed the same...

  12. MAT u/s 115JB - The findings of the ld.CIT(A) holding the impugned expenses to be not in the nature of prior period expenses, but confirming the adjustment made to the...

  13. Allocating unallocable expenses to each segment in proportion to segmental turnover to total turnover - all common expenses cannot be apportioned in the universal ratio...

  14. Assessment u/s 153C - disallowance made u/s 37. Assessing Officer observed no supporting evidence for claimed expenses furnished by assessee and non-cooperation during...

  15. Valuation of imported goods - Halani Star - rejected of declared Cost, Insurance and Freight (CIF) value value - When neither the Chartered Engineer was examined nor the...

 

Quick Updates:Latest Updates