Home Highlights April 2016 Year 2016 This

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1. Computation of Profit Level Indicator (PLI), being, the Operating Profit/Total Cost (OP/TC) of the assessee -Like debts becoming bad from the sale of goods assuming the...

2. TP Adjustment - PLI computation - if rental expenditure is considered as an operating expenditure, then the reimbursement should be set off against the rental...

3. External Commercial Borrowings (ECB) Policy – Non-Banking Financial Company – Infrastructure Finance Companies (NBFC-IFCs) - Circular

4. TP Adjustment - ALP determination - depreciation - operating cost - since the assets are used by the assessee with respect to the services provided to AE and hence the...

5. TP Adjustment - The main contention was whether forex losses should be considered as non-operating or operating for the purpose of computing the Profit Level Indicator...

6. Adjustment towards foreign exchange fluctuation - non-consideration of impact of abnormal movement in the foreign exchange rates while computing the operating profit...

7. Deduction u/s 80IA - whether assessee fulfilled the condition of sub-Section (4)(i)(b) of Section 80IA? - partnership firm was converted into a company - For the...

8. Income from the nature of interest received by the assessee in DRDO/ISRO accounts (for short ‘FD A/cs’) - the assessee, DRDO/ISRO are either Government Departments or...

9. Disallowance u/s 36(1)(iii) - claim of interest expenditure - The companies GIL and CNIL are subsidiary companies, which clearly indicates that the investment made by...

10. TP adjustment - Inclusion of excise duty on the operating revenue for two comparables - By including excise duty in the case of two comparables by the ld. TPO, the...

11. Additions as interest income - compensation received by the assessee - As the business of assessee was set up and had started and there was huge investment made by...

12. TP adjsutment - “AE” investment banking activities - comparable selection - The persistence loss- making company are normally excluded as comparable. As per the...

13. Interest on refunds u/s 244A - Having availed the time for rectifying the defects and claiming interest for the defect rectification time is unavailable. Such an...

14. Disallowance on account of cost of improvement while computing the capital gain - The amount of interest paid by the assessee constitutes the actual cost to the assessee...

15. Non-Banking Financial Company (NBFC) categorization - Amendment made in sec 43B and 43D to substitute the words, “a deposit taking non-banking financial company or...