TPO's adjustment on equipment purchases from associated ...

Transfer Pricing Adjustment Deleted After Assessee Proves Equipment Purchase Authenticity Through Laboratory Bills and Documentation

February 27, 2025

Case Laws Income Tax AT

TPO's adjustment on equipment purchases from associated enterprise was deleted. Tribunal found assessee had produced all relevant bills for laboratory equipment purchases before DRP and TPO, establishing transaction authenticity. Since documentary evidence conclusively proved actual equipment purchases occurred, no grounds existed for transfer pricing adjustment. TPO's basis for adjustment was invalidated as bills clearly demonstrated genuine equipment procurement transactions with AE. ITAT ruled adjustment was unwarranted when supporting purchase documentation had been furnished, thereby nullifying the entire TP addition made by TPO.

View Source

← Previous Next →

TPO's adjustment on equipment purchases from associated ...

Transfer Pricing Adjustment Deleted After Assessee Proves Equipment Purchase Authenticity Through Laboratory Bills and Documentation

February 27, 2025

Case Laws Income Tax AT

You may also like:

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

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)...

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

Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

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

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

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...

Transfer pricing adjustment deleted - the comparables adopted by the assessee are uncontrolled parties and can be considered for the purpose of determining the Arms'...

CIT(A) determined profit at 5.47% on total purchases. Assessee produced sufficient evidence regarding purchases, movement of goods, GST payment on transportation,...

TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned...

Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

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

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...

Quick Updates: