Home Highlights June 2013 Year 2013 This

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1. 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...

2. TP Adjustment - CIT(A) under the garb of "rule of consistency" adopted the TP analysis made by the TPO - This method of TP analysis is unheard of as every assessment...

3. Disallowance being amount of State Value Added Tax (VAT) paid for earlier years - Deduction u/s 80IB claimed - Assessee became liable to pay VAT for earlier years - The...

4. TP adjustment - royalty paid by the assessee to its AE - selection of MAM - The method of the assessee can be pigeonholed in the “other method” provided in Rule 10AB r.w....

5. 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...

6. Disallowance on account of foreign exchange fluctuation loss - It is an undisputed fact that for the assessment year 2012-13, 2013-14 and 2016-17, the assessee declared...

7. TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

8. TP adjustment - TNMM VS RPM - neither the TPO nor learned DRP has pointed out any other defect in the transfer pricing analysis of the assessee except that the assessee...

9. Deduction us.37(1) on account of “Escrow Disbursement Provision” ('EDP’) - Prior period expenditure - To put it simply, the AO will bifurcate total Escrow Disbursement...

10. Disallowing interest u/s. 36(1)(iii) - CIT(A) allowed the claim - AO is drawing adverse inference that assessee has not submitted the utilization of the overdraft in the...

11. 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)...

12. Difference in stock valuation - valuation of the closing stock - LIFO or FIFO method - It is an admitted case that the assessee has been continuously adopting the LIFO...

13. TP Adjustment - Selection of MAM - transactional net margin method is the most appropriate method, the TPO is directed to examine the international transactions entered...

14. TP Adjustment - International transactions with its AEs for providing software consultancy services - Selection of MAM - DRP without appreciating the above facts, has...

15. TP adjustment in respect of management fee - When the TPO alleges that the assessee has not received any of the above services, it would indicate that the very...