Home Highlights June 2014 Year 2014 This

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

2. TP Adjustment - Receipt of royalty income from its associated enterprises - when the approach adopted by the assessee is found to be acceptable, the adjustment...

3. Transfer pricing adjustment – When the indent/commission transaction with the associated enterprises is to be benchmarked, the same should be done with indent/...

4. Transfer pricing adjustment - international transaction relating to acquisition of intangible assets by assessee from its associated enterprise - All the additions...

5. Transfer pricing adjustment – export to associated enterprises of spares and components required for the purpose of servicing of vehicles sold by assessee - the...

6. Applicability of Transfer pricing provisions - Transactions with joint venture - transactions between the assessee and IJMII do not fall under section 92B(2) -...

7. TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

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

9. For the purpose of transfer pricing adjustment, the transaction of the assessee with Associated Enterprise outside the country alone has to be taken into consideration....

10. Transfer Pricing (T.P) adjustments - notional interest on receivables from Associated Enterprises (A.E) - the credit period extend by the assessee to its AE is very...

11. TP Adjustment - As per the provisions of aforesaid Rule, the ‘other method’ shall be the method which takes into account the price which has been or would have been...

12. Transfer pricing adjustment - arm‘s length pricing of international transactions - Advertising / Marketing and Promotion Expenses - international transaction - Domestic...

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

14. TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from...

15. Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...