TP Adjustment - MAM - Considering brokerage rate of all Non-AEs ...

Income Tax

January 24, 2024

TP Adjustment - MAM - Considering brokerage rate of all Non-AEs for the comparability purposes - Arm's Length Price (ALP) of broking commissions - The Tribunal directed the Transfer Pricing Officer (TPO) to consider both overseas and domestic clients while applying the Comparable Uncontrolled Price (CUP) method. Adjustment of 40% was allowed on marketing and research costs. - AT

View Source

← Previous Next →

TP Adjustment - MAM - Considering brokerage rate of all Non-AEs ...

Income Tax

January 24, 2024

You may also like:

TP Adjustment - adjustment of brokerage income - assessee also filed submission before the TPO providing detailed explanation with regard to the differences in services...

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...

TP Adjustment - MAM - Management consultancy services - The tribunal noted discrepancies in how services were valued between Associated Enterprises (AE) and Non-AEs. The...

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

TP Adjustment - comparability adjustment on account of abnormal cost - There is no dispute on part of the revenue that in the BPO industry the prevalent rate for...

TP Adjustment - MAM Adjustment - ALP adjustment -In TNMM what is to be seen is the functional comparability and not the product comparability. Further, it is observed...

Transfer Pricing - adjustment to ALP - addition - consideration of transactions both with AEs and Non-AEs for the purpose of recommending adjustment - AT

TP Adjustment - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of...

TP Adjustment - goods sold to Associated Enterprises (AEs) - NP Determination - The TPO has not given any reason as to why he did not consider above said two expenses...

TP Adjustment - rate of interest on loan availed from AE - when the prime lending rate itself had increased over the years and stood at 14.55% for the relevant period,...

TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

TP Adjustment - arm’s length price of interest on short term loan granted to the AE - The fact that the assessee has provided a short term loan only for a period of 15...

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...

Imposition of penalty u/s 271G - failure to furnish information or documents in respect of segmental amount relating to transaction made with AEs and non-AEs for...

TP Adjustment - re-computing the Arm’s Length price (ALP) of Salary payments made to related parties - payment of remuneration to the related persons - the employees...

Quick Updates: