TP Adjustment - Adjustment in respect of credit period - the ...

Income Tax

May 31, 2022

TP Adjustment - Adjustment in respect of credit period - the contentions of Revenue and Assessee have not been thoroughly examined by the Ld. CIT(A) in proper perspective. We also observe that no remand report was called for by the Ld. CIT(A) to appreciate the contentions of Revenue as well as the Assessee. In the interest of justice we restore this ground to the file of the Ld. AO/TPO for denovo adjudication in accordance with law after providing adequate opportunity of being heard to the assessee. Grounds of appeal of the Revenue is allowed for statistical purpose. - AT

View Source

← Previous Next →

TP Adjustment - Adjustment in respect of credit period - the ...

Income Tax

May 31, 2022

You may also like:

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...

TP Adjustment - Impute interest on receivables - LIBOR + 200 basis point rate is most appropriate rate and hence, direct the AO/TPO to adopt LIBOR + 200 basis point for...

TP Adjustment - Assessee contents that part of the Revenue reported in future years, but the contention of the assessee cannot be accepted for the simple reason that...

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 - 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...

TP adjustment regarding interest on outstanding receivables - “interest on receivables” is an international transaction during the FY and the decisions rendered prior to...

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 - secondment of employees by Assessee to its AE - the benchmarking done by the TPO by applying the same rate of thirty party placement agency is not...

TP adjustment - Determining the Arm's Length Price of international transactions in respect of "advisory services" - we adopt judicial consistency in the absence of any...

TP Adjustment - ALP determination qua domestic transactions entered into by the assessee with its partner u/s 92BA(i) of the Act - no addition on account of TP...

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

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...

TP Adjustment - amount disallowed by the AO, viz., Product development expenses, provision for customer claims should be excluded from the cost while computing margin of...

TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

Quick Updates: