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 January 2023 Year 2023 This

TP Adjustment - Receipt of royalty income from its associated ...

Income Tax

January 12, 2023

TP Adjustment - Receipt of royalty income from its associated enterprises - when the approach adopted by the assessee is found to be acceptable, the adjustment determined by the learned transfer-pricing officer in the remand report deserves to be accepted. Accordingly we direct the learned AO to restrict the addition on account of arm’s-length price of the international transaction of receipt of royalty income from Vietnam associated enterprise of the assessee - AT

View Source

 


 

You may also like:

  1. TP Adjustment - The Legislature has never shown an intention to treat the same international transaction in two different ways in the hands of two associated enterprises...

  2. TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

  3. TP Adjustment - assessee has issued the corporate guarantee on behalf of AE’s - interest saved approach - The ITAT decided in favor of the assessee, directing the AO to...

  4. TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

  5. TP Adjustment - ALP adjustment qua receipt of management services - the assessee has already filed its detailed paper book in the nature of supportive evidence...

  6. TP Adjustment - Rejection of Associated Enterprises as the tested party - foreign Associated Enterprises satisfied all the criteria for being taken as a tested party....

  7. TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from...

  8. 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...

  9. TP adjustment on account of interest paid by the assessee on behalf of the associated enterprise - the payment of interest by the assessee, on behalf of the associated...

  10. TP Adjustment - ALP of interest on NDC’s [Non-convertible debentures] - NCD issued to associated enterprise is unsecured and loans taken from third parties are secured...

  11. TP Adjustment - international transaction involving payment of royalty undertaken by Diesel India with its Associated Enterprise (“AE”) - the arithmetic mean of...

  12. TP Adjustment - corporate guarantee provided on behalf of Associated Enterprises - These two kinds of guarantees are materially different, as has been held by a series...

  13. TP Adjustment - the TPO is erred in adopting CUP method for few transactions when he has accepted overwhelming majority of transactions under TNMM method. The DRP...

  14. Transfer pricing adjustment – When the indent/commission transaction with the associated enterprises is to be benchmarked, the same should be done with indent/...

  15. TP Adjustment - Fair market value of share of ECL representing the ALP - the DCF Method could not be adopted in the facts and circumstances of the present case as the...

 

Quick Updates:Latest Updates