TP adjustment - upward adjustment in imputing notional interest ...

Income Tax

September 14, 2022

TP adjustment - upward adjustment in imputing notional interest on the outstanding overdue receivables from Associated Enterprises - working capital adjustments on the ALP has been already factored in its pricing / profitability vis-à-vis that of its comparables - any further adjustment to the margin of the assessee on the outstanding receivables cannot be justified and no separate upward adjustment on outstanding export receivables is required - AT

View Source

← Previous Next →

TP adjustment - upward adjustment in imputing notional interest ...

Income Tax

September 14, 2022

You may also like:

TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

TP Adjustment - when TNMM method has been applied as most appropriate method it could take care of all notional interest costs wherever it could be applied and there...

TP Adjustment - interest on delayed receivables - Assessee pleaded that the deferred receivables do not constitute a separate international transaction requiring...

TP Adjustment - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of...

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...

Transfer Pricing Adjustment - Adjustment on account of notional interest on the receivables - when the assessee is having their own funds and not paying interest on any...

Appropriate rate for benchmarking - receivables from AEs - it would be most appropriate if the LIBOR rate is applied as most appropriate rate of interest for imputing...

TP Adjustment - Interest on interest outstanding/interest receivable - The interest on a loan is a compensation received towards the utilisation of funds given by the...

TP Adjustment - Notional interest on overdue receivables - number of days outstanding beyond the grace period for each and every invoice. - If there are no agreements...

TP Adjustment - interest on receivables - by permitting the AE to hold on to the payments, the assessee has allowed the AE to reap financial benefit at the cost of...

TP Adjustment - Notional interest - interest-free advances extended by the assessee to its AE - In an uncontrolled condition and between persons other than associated...

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

Transfer Pricing (T.P) adjustments - notional interest on receivables from Associated Enterprises (A.E) - the credit period extend by the assessee to its AE is very...

TP Adjustment - interest on outstanding receivables - The realization of invoices were made with abnormal delay. This, in our considered opinion, tantamount to indirect...

TP Adjustment - Eligible International Transaction - safe harbor rules - The court examined the eligibility of international transactions under Rule 10TC of the Income...

Quick Updates: