TP Adjustment - Grant of negative working capital adjustment - ...

Case Laws Income Tax

February 8, 2021

TP Adjustment - Grant of negative working capital adjustment - Since the assessee does not have any working capital risk, the question of negative working capital does not arise - TPO is directed to compute the ALP in the light of the directions as given above, after affording Assessee opportunity of being heard. - AT

View Source

← Previous Next →

TP Adjustment - Grant of negative working capital adjustment - ...

Case Laws Income Tax

February 8, 2021

You may also like:

TP Adjustment - Working capital adjustment - there is no need for making any negative working capital adjustment, when assessee does not carry on with any working...

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

TP Adjustment - No adjustment towards working capital has been allowed to the assessee - One has to see that reasonable adjustment is being made so as to bring both...

TP Adjustment - Working capital adjustment - Making a working capital adjustment is an attempt to adjust for the differences in time value of money between the tested...

TP Adjustment - Adjustment on account of working capital adjustment - Guidance on comparability adjustments is found in paragraphs 3.47-3.54 and in the Annexure to...

TP Adjustment - Working capital adjustment for computing the margin of the comparables - in keeping with the OECD guidelines, endeavor should be made to bring in...

Determination of arm’s length price (ALP) - TPA - working capital adjustment has to be allowed based on the working capital requirements of the assessee and the...

TP Adjustment - non granting of adjustment on import duty - as necessary consumption of the material is only booked in the profit and loss account for which the...

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...

Transfer pricing adjustment - Risk adjustment and negative working capital adjustment - Though, it may be true, in case of a captive service provider AE takes all major...

Negative working capital - It is the contention of the assessee that the negative working capital should be ignored, since the assessee is a risk free enterprise -...

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)...

TP adjustment - upward adjustment in imputing notional interest on the outstanding overdue receivables from Associated Enterprises - working capital adjustments on the...

TP Adjustment - apportioning the expenses of assessee’s affiliates - Also noted that the assessee has received certain services from its AE which has been treated by the...

TP Adjustment - negative working capital adjustment shall not be made in case of a captive service provider as there is no risk and it is compensated on a total cost...

Quick Updates: