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Income Tax - Highlights / Catch Notes

Home Highlights June 2013 Year 2013 This

Transfer Pricing Adjustment - companies with a small turnover of ...

Income Tax

June 22, 2013

Transfer Pricing Adjustment - companies with a small turnover of Rs.25 lacs cannot be held to be comparable in this case. - AT

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  1. Transfer pricing adjustment - the addition of ₹ 15.18 lac on account of interest on the deemed loan due to under-receipt of share premium cannot be sustained - AT

  2. Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

  3. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

  4. Transfer pricing adjustment - Reworking of the operating margin - apportionment of cost has to be done on man-hour basis and not on turnover basis - AT

  5. TPA - determination of ALP - TP adjustment by applying Bright Line Test (BLT) is not sustainable on protective basis having no statutory mandate.

  6. 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...

  7. TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned...

  8. Transfer pricing adjustment – export to associated enterprises of spares and components required for the purpose of servicing of vehicles sold by assessee - the...

  9. Transfer pricing adjustment – Guarantee charges for guarantee to AE – no upward adjustment in the ALP in relation to charging of guarantee commission over and above...

  10. Transfer Pricing - adjustment to ALP - addition - consideration of transactions both with AEs and Non-AEs for the purpose of recommending adjustment - AT

 

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