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Income Tax - Highlights / Catch Notes

Home Highlights March 2019 Year 2019 This

TP Adjustment - AMP expenses by applying bright line test on ...

Income Tax

March 1, 2019

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 statutory mandate.

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  2. TP Adjustment - excessive AMP expenses - third party also benefits - Revenue also could not demonstrate the presence of any machinery provision to compute Arm’s Length...

  3. TP Adjustment - international transaction - in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur AMP expenses,...

  4. TP Adjustment - MAM - adjustment made towards the AMP expenses by adopting an approach similar to bright line test - if the net profit margin meets the Arm's length...

  5. Transfer Pricing Adjustment - adjustment against AMP expenditure - Bright Line Test (BLT) - BLT method as adopted by Ld. TPO was not a valid method to benchmark the...

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  9. TPA - AMP expenses - Revenue has not been able to demonstrate that there exists an international transaction involving the Assessee and a foreign AE on the question of...

  10. Transfer pricing adjustment - There can be no mark-up on reimbursement of expenses incurred by the assessee prior to incorporation of NDTV Network Plc UK - AT

 

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