TP Adjustment - assessee has issued the corporate guarantee on ...

Case Laws Income Tax

March 21, 2024

TP Adjustment - assessee has issued the corporate guarantee on behalf of AE’s - interest saved approach - The ITAT decided in favor of the assessee, directing the AO to restrict the addition by splitting the interest benefit on a 50:50 basis between the guarantor and the borrower. It was noted that earlier years' tribunals had accepted a splitting of the interest savings as a reasonable approach. - With regard to Royalty, the ITAT allowed the assessee's grounds concerning TP adjustments related to the charge of brand royalty, following earlier tribunal decisions that set specific rates for such royalties.

View Source

← Previous Next →

TP Adjustment - assessee has issued the corporate guarantee on ...

Case Laws Income Tax

March 21, 2024

You may also like:

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...

The ITAT addressed two main issues: 1. TP Adjustment for corporate guarantee to AE: As the assessee did not provide guarantees to unrelated parties, it was not a...

TP adjustment on account corporate guarantee provided by the assessee to its AE - no transfer pricing adjustment could be made with regard to corporate guarantee issued...

TP Adjustment - Arm's length price of the corporate guarantee fee - Lower authorities have also included a letter of comfort as part of corporate guarantee - We reject...

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 commission on letter of credit - international transaction or not? - CIT (A) appreciated the difference between corporate guarantee and Letter of Comfort....

TP Adjustment in respect of extension of performance/ corporate guarantee - Even if it is reckoned as international transaction, then also on FAR analysis and looking to...

Transfer Pricing Adjustments on Corporate Guarantee Charges, Interest on Optionally Convertible Loans (OCL), and Reimbursement of Expenses. - The Tribunal found that...

TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of...

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

TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result...

TP Adjustment - corporate guarantee given by the assessee company to its AEs - the corporate guarantee commission is an international transaction and should be charged @...

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...

Demand of service tax - providing services without consideration (free) to its associate companies - activity of giving corporate guarantee - The Show Cause Notice...

This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

Quick Updates: