Home Highlights November 2014 Year 2014 This

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1. 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) -...

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

3. 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

4. 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...

5. Capital gain on sale of shares - market price or agreed price - transfer of shares by obtaining interest free loans for a long tenure coupled with call option agreements...

6. Transfer pricing - the transaction in the instant case of sale of shares in ‘AB’ International will have to be benchmarked as per the transfer pricing provisions...

7. 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...

8. The Tribunal meticulously analyzed each issue, heavily relying on precedent ITAT decisions and the specifics of the case presented. For the major contentious points,...

9. TPA - This is a case in which transfer pricing provisions cannot be applied because the application of ALP adjustment will indeed result in erosion of Indian tax base-...

10. 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...

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

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

13. Transfer pricing adjustment - adjustment made on account of sharing of software expenses with the AE - no reason why adjustment should be made on account of sharing of...

14. Genuineness of sale price of shares - transfer of same share at different price - a much higher price in the hands of Empee Sugars & Chemicals Ltd., was undoubtedly to...

15. Transfer Pricing Adjustment - Transfer Pricing Regulations do not contemplate taking into account future data for the purpose of bench marking - AT