The ITAT allowed the assessee's grounds regarding TP adjustment ...

Assessee wins on TP adjustment for interest on AE receivables, amalgamation expenditure; Interest relief under 234B, 234C.

December 20, 2024

Case Laws Income Tax AT

The ITAT allowed the assessee's grounds regarding TP adjustment for interest on outstanding receivables from AEs and deduction u/s 35DD. It held that no separate interest on receivables is required to be imputed as the assessee is a debt-free company and working capital adjustment was granted, relying on the decisions in Boeing India and Kusum Health Care. On deduction u/s 35DD, it directed the AO to allow 1/5th of amalgamation expenditure based on the Supreme Court's decision in Goetze India. The ITAT also held that interest u/s 234B is consequential, and u/s 234C should be charged only on returned income, not assessed income.

View Source

← Previous Next →

The ITAT allowed the assessee's grounds regarding TP adjustment ...

Assessee wins on TP adjustment for interest on AE receivables, amalgamation expenditure; Interest relief under 234B, 234C.

December 20, 2024

Case Laws Income Tax AT

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...

Transfer pricing adjustment - No interest having been charged by the assessee to the non-AE outstandings, its transaction of outstanding receivables with AE without...

TP Adjustment - Interest on interest outstanding/interest receivable - The interest on a loan is a compensation received towards the utilisation of funds given by the...

TP Adjustment - addition on account of notional interest on export receivables - When the assessee is adopting the uniform policy for none charging interest on export...

TP Adjustment - interest on receivables - by permitting the AE to hold on to the payments, the assessee has allowed the AE to reap financial benefit at the cost of...

TP Adjustment - delayed receivables from AE - re-characterizing the delay in receipt of receivables as unsecured loan, the AO computed interest by applying rate of 4.33%...

TP Adjustment - interest on outstanding receivables - The realization of invoices were made with abnormal delay. This, in our considered opinion, tantamount to indirect...

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...

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...

Transfer Pricing Adjustment - Adjustment on account of notional interest on the receivables - when the assessee is having their own funds and not paying interest on any...

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

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

TP Adjustment - Impute interest on receivables - LIBOR + 200 basis point rate is most appropriate rate and hence, direct the AO/TPO to adopt LIBOR + 200 basis point for...

Quick Updates: