Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights December 2020 Year 2020 This

TP Adjustment - adjustment on account of AMP - we cannot infer ...

Income Tax

December 16, 2020

TP Adjustment - adjustment on account of AMP - we cannot infer the existence of international transactions qua AMP expenses between taxpayer and AE beyond the reimbursement already made by the AE under MDF Agreement. - AT

View Source

 


 

You may also like:

  1. TP adjustment - AMP expenses - the existence of an international transaction will have to be established de hors the BLT, the burden is on the Revenue to first show the...

  2. TP Adjustment - existence of international transaction of AMP Expenses - the revenue has also substantially proved the onus of existence of international transaction...

  3. 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...

  4. 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,...

  5. TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the...

  6. TP Adjustment - adjustment made on account of advertisement, marketing and promotion (AMP) expenses - internatinal transaction - the AMP expenditure incurred by the...

  7. TP adjustment on account of AMP expenditure - International transaction u/s 93B - Unless it was shown that there was such an arrangement which resulted into any direct...

  8. TP Adjustment - international transactions u/s. 92B or not - In absence on any such agreement, the first and primary condition of holding the transaction in question as...

  9. TP Adjustment - adjustment on account of AMP expenditure - We are unable to accept the said contention of the learned counsel for the Revenue that since the Assessee...

  10. TP Adjustment - US Transactions non US Transactions - scope of MAP agreement - It would be better to refer to the settlement arrived between the competent authority of...

  11. TP adjustment on account of back-to-back counter bank guarantee - TPO, by considering the rate charged by Bank of Baroda for issuance of guarantee against 100% counter...

  12. TP Adjustment Transaction of slump sale between the subsidiaries of Foreign Holding Company - To be considered as an international transaction or not - The meaning of...

  13. 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...

  14. TP Adjustment - International transactions with its AEs for providing software consultancy services - Selection of MAM - DRP without appreciating the above facts, has...

  15. TP adjustment in Distribution activity, described as ESAS - ALP and the consequential transfer pricing adjustment are contemplated only in respect of the international...

 

Quick Updates:Latest Updates