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 January 2023 Year 2023 This

TP Adjustment - Assessee's main activity is nothing but ...


Tax Authority Confirms Additions: Assessee's Role Limited to Marketing; AE Retains Product Ownership, Decision-Making, and Pricing Authority.

January 27, 2023

Case Laws     Income Tax     AT

TP Adjustment - Assessee's main activity is nothing but marketing activity, whereas all the ownership of the product, the power to determine whether to accept / reject the order and the pricing is with the AE. The assessee is only getting 3.5% of the revenue from the receipts of the customers for the marketing function that it is doing. - Additions confirmed - AT

View Source

 


 

You may also like:

  1. Addition made u/s 153A on account of undisclosed foreign bank account and interest income thereon - assessee confronted with client profiles from HSBC Bank showing...

  2. Scope of limited scrutiny - cash deposits in the Bank accounts being more than the turnover - The impugned addition made by the AO on account of profit allegedly earned...

  3. The case pertains to the scope of limited scrutiny by the assessing officer regarding computation of capital gains u/s 45 and providing exemption u/s 54B of the Income...

  4. The Appellate Tribunal upheld the addition u/s 68 as the assessee failed to establish the identity, creditworthiness, and genuineness of transactions with Shri Singla...

  5. Estimation of business income - The learned CIT (A) confirmed addition merely harping on non-compliance by assessee before the Assessing Officer and not applying his...

  6. The case involved the scope of limited scrutiny and the validity of a notice u/s 143(2) of the Income Tax Act. The assessee's case was selected for limited scrutiny to...

  7. Liability to pay service tax for services provided to a foreign entity. The appellant argued that their turnover within the domestic market was below the threshold...

  8. Addition u/s. 69 based on information received from Australian Tax authorities - There is absolutely no other material in the hand of the A.O. of proving the addition in...

  9. The assessee, a foreign company, earned network transportation fees from its Indian associated enterprise (AE), Damco India Private Limited (DIPL). The Assessing Officer...

  10. The ITAT partially allowed the taxpayer's appeal concerning comparable selection for transfer pricing adjustments. The Tribunal excluded Tata Elxsi Limited (significant...

  11. Addition u/s 56 (2)(viib) - Valuation of shares - Faire Market Value (FMV) - the assessee has himself filed a valuation certificate before AO and accepted fair market...

  12. Addition u/s 56(2)(viia) - shares received by the assessee company on account of amalgamation, for a price lower than the Fair Market Value (F.M.V) of the shares -...

  13. Interpretation of statute - Levy of VAT - credit note received subsequent to the date of the invoice - Determination of Turnover - Input Tax Credit - Large Bench...

  14. This case deals with the levy of penalties u/ss 271AAA and 271(1)(c) of the Income Tax Act in relation to various additions made to the assessee's income based on seized...

  15. Imposition of penalty u/s 271(1)(c) of the Income Tax Act for two types of additions: (1) the addition made u/s 50C on the difference between stamp duty value and sale...

 

Quick Updates:Latest Updates