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 March 2023 Year 2023 This

TP Adjustment - Recover of salary expenses - benefit to the ...

Case Laws     Income Tax

March 17, 2023

TP Adjustment - Recover of salary expenses - benefit to the assessee with the deputation of technical expert - DRP has mentioned that the deputation of the technical expert can only be for a definite purpose to benefit the AE and benefit from the expertise and productivity of these experts while depriving the assessee of their services. - order of DRP sustained - AT

View Source

 


 

You may also like:

  1. 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...

  2. TP Adjustment - Recovery of expenses represent expenses incurred by the assessee company on behalf of AE towards Bid bond expenses. These expenses were also recovered by...

  3. 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...

  4. 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...

  5. TP Adjustment - Addition as ‘Fees for Technical Services’ ignoring the assessee’s contention that it was purely reimbursement received for Construction and Management...

  6. TP Adjustment - AMP expenses by applying bright line test on protective basis - TP adjustment amounting by applying BLT is not sustainable on protective basis having no...

  7. 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)...

  8. Additions (Benefit) u/s 28(iv) - Expenditure incurred by the HO for salary paid to the expatriate employees for rendering services to PE - The tribunal upheld the...

  9. 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...

  10. 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,...

  11. 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...

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

  13. 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...

  14. 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...

  15. 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...

 

Quick Updates:Latest Updates