ITAT adjudicated multiple transfer pricing (TP) issues involving ...

Transfer Pricing Triumph: Tribunal Strikes Down Arbitrary Adjustments, Validates Arm's Length Transactions Under Comprehensive Review

April 24, 2025

Case Laws Income Tax AT

ITAT adjudicated multiple transfer pricing (TP) issues involving associated enterprises (AEs) transactions. The Tribunal comprehensively deleted TP adjustments related to external commercial borrowing (ECB) interest, royalty payments, and trade receivables/payables. Key holdings include: (1) ECB interest at LIBOR+500 basis is arm's length, (2) royalty payment determination at Nil is arbitrary, and (3) netting off notional interest considering both receivables and payables is appropriate. The Tribunal set aside CPC's mechanical adjustments, directing the Assessing Officer to verify suo-moto disallowances and employee contribution issues in accordance with established legal principles and recent judicial precedents.

View Source

← Previous Next →

ITAT adjudicated multiple transfer pricing (TP) issues involving ...

Transfer Pricing Triumph: Tribunal Strikes Down Arbitrary Adjustments, Validates Arm's Length Transactions Under Comprehensive Review

April 24, 2025

Case Laws Income Tax AT

You may also like:

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...

ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely...

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)...

The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The...

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

ITAT adjudicated transfer pricing dispute regarding comparable company selection. The tribunal determined the Arm's Length Price (ALP) computation by the Transfer...

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...

ITAT remanded the case to the AO for compliance with DRP's directive regarding transfer pricing adjustment. The tribunal acknowledged the DR's concession that the AO had...

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

Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

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

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)...

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

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

Quick Updates: