TP Adjustment - international transactions u/s. 92B or not - In ...

Case Laws Income Tax

January 14, 2023

TP Adjustment - international transactions u/s. 92B or not - In absence on any such agreement, the first and primary condition of holding the transaction in question as an international transaction remains to be fulfilled. As the assessee cannot be held liable for expenses incurred on advertising marketing and promotion as an international transaction of AMP, the consequent benchmarking by the Ld. TPO is also not justified. - AT

View Source

← Previous Next →

TP Adjustment - international transactions u/s. 92B or not - In ...

Case Laws Income Tax

January 14, 2023

You may also like:

TP Adjustment Transaction of slump sale between the subsidiaries of Foreign Holding Company - To be considered as an international transaction or not - The meaning of...

TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the...

TP adjustment - AMP expenses - the existence of an international transaction will have to be established de hors the BLT, the burden is on the Revenue to first show the...

TP Adjustment - US Transactions non US Transactions - scope of MAP agreement - It would be better to refer to the settlement arrived between the competent authority of...

TP adjustment regarding interest on outstanding receivables - “interest on receivables” is an international transaction during the FY and the decisions rendered prior to...

TP Adjustment - existence of international transaction of AMP Expenses - the revenue has also substantially proved the onus of existence of international transaction...

TP Adjustment - international transaction - in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur AMP expenses,...

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

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

TP adjustment on account of AMP expenditure - International transaction u/s 93B - Unless it was shown that there was such an arrangement which resulted into any direct...

TP Adjustment - corporate guarantee - international transaction of not? - the issue of corporate guarantee were in the nature of share holder activity and the same could...

TP adjustment in Distribution activity, described as ESAS - ALP and the consequential transfer pricing adjustment are contemplated only in respect of the international...

TP Adjustment - International transactions with its AEs for providing software consultancy services - Selection of MAM - DRP without appreciating the above facts, has...

TP adjustment - Determining the Arm's Length Price of international transactions in respect of "advisory services" - we adopt judicial consistency in the absence of any...

TP Adjustment - International transaction - The only promise made by the assessee is, it will not make any divestment of the shares during the currency of the loan. In...

Quick Updates: