Home Highlights May 2015 Year 2015 This

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1. TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...

2. TP adjustment on account of payment of overseas support fee - The assessee has its head office outside India and the decision, on the basis of which the assessee gets...

3. TP Adjustment - Design Engineering Services - in the TP study report assessee applied margins at the entity level - it cannot be precluded from furnishing segmental...

4. TP Adjustment - main grievance is the non-granting of the adjustment with regard to underutilized capacity - The settled law is that adjustment on account of capacity...

5. TP Adjustment - ALP adjustment qua receipt of management services - the assessee has already filed its detailed paper book in the nature of supportive evidence...

6. Disallowance u/s 40 (a) (iib) - payment of Gallonage Fee, Licence fee, Shop rental (Kist) and Surcharge on Sales Tax - the levy of Gallonage Fee with respect to the...

7. Income accrued in India - Referral fees - considering that the referral activity was undertaken outside India and assessee’s Mumbai branch (PE) had no role to play in...

8. Admissibility of expenditures incurred by the assessee (a pharmaceutical company) u/s 37 - disallowance of referral fees paid to doctors in violation of public policy...

9. Disallowance of referral fees paid - The payment was at arm’s length, AO cannot reassess that issue or draw adverse conclusions from the percentage value of the referral...

10. TP adjustment - specified domestic transactions (SDT) - The ITAT held that since the provision (Section 92BA(i)) was omitted without a saving clause effective from...

11. TP Adjustment - the TPO is erred in adopting CUP method for few transactions when he has accepted overwhelming majority of transactions under TNMM method. The DRP...

12. TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result...

13. TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of...

14. TP Adjustment - AMP expenses by applying bright line test on protective basis - TP adjustment amounting by applying BLT is not sustainable on protective basis having no...

15. TP Adjustment - CIT(A) under the garb of "rule of consistency" adopted the TP analysis made by the TPO - This method of TP analysis is unheard of as every assessment...