Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights April 2025 Year 2025 This

The ITAT allowed the assessee's appeal, directing the AO to ...


Transfer Pricing Win: Assessee Succeeds in Challenging Tax Adjustments, Methodology, and Capital Gain Computations

April 9, 2025

Case Laws     Income Tax     AT

The ITAT allowed the assessee's appeal, directing the AO to reconsider multiple transfer pricing and tax-related adjustments. Key holdings include: (1) deletion of TP adjustments in SWD and test/measurement equipment segments, (2) accepting the assessee's profit level indicator methodology, (3) setting interest rate at LIBOR + 200 basis points, (4) directing reassessment of CSR expenditure under section 80G, (5) remanding long-term capital gain computation for fresh hearing, and (6) instructing verification of TDS credit from merged entity. The tribunal comprehensively upheld the assessee's contentions, providing procedural relief and mandating detailed reconsideration by lower authorities.

View Source

 


 

You may also like:

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

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

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

  4. 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)...

  5. ITAT adjudicated transfer pricing dispute involving international transactions between an assessee and its Associate Enterprise. The tribunal upheld the transfer pricing...

  6. 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) -...

  7. ITAT adjudicated transfer pricing dispute involving manufacturing and service segments. Tribunal found substantial merit in assessee's contentions regarding arm's length...

  8. HC determined that AMP expenditure does not constitute a separate international transaction requiring transfer pricing adjustment. The Tribunal consistently applied...

  9. The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

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

  11. 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...

  12. 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...

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

  14. 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

  15. The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

 

Quick Updates:Latest Updates