Transfer Pricing Adjustment - Arm's Length Adjustment to Income ...

Case Laws Income Tax

March 26, 2024

Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The Tribunal emphasized the need for proper benchmarking in determining the arm's length price for these transactions, directing remands to the Assessing Officer and Commissioner for reevaluation. Overall, the appeals were allowed for statistical purposes, with the Tribunal providing detailed instructions for reassessment based on appropriate benchmarks.

View Source

← Previous Next →

Transfer Pricing Adjustment - Arm's Length Adjustment to Income ...

Case Laws Income Tax

March 26, 2024

You may also like:

Transfer pricing adjustment towards notional guarantee commission chargeable for the guarantee extended to its associated enterprises - commission chargeable for...

Transfer price adjustment - Bank guarantee commission - There was a clear benefit accrued to the Associated Enterprises by the guarantee provided by the assessee and...

The High Court upheld the Income Tax Appellate Tribunal's (ITAT) decision regarding the applicability of Section 92(3) in determining the arm's length price for...

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment...

Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

Transfer pricing - the issuance of corporate guarantees is covered by the residuary clause of the definition under section 92B of the Act but since such issuance of...

TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

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...

Transfer pricing adjustment – Guarantee charges for guarantee to AE – no upward adjustment in the ALP in relation to charging of guarantee commission over and above...

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

Quick Updates: