Transfer pricing - Pre-operative expenses - In absence of any ...

Income Tax

February 8, 2014

Transfer pricing - Pre-operative expenses - In absence of any material to prove that the assessee has recovered the pre-operative expenses from its AE, the conclusion arrived at by the departmental authorities is merely on presumption and surmises - AT

View Source

← Previous Next →

Transfer pricing - Pre-operative expenses - In absence of any ...

Income Tax

February 8, 2014

You may also like:

Denial of claim of loss or to categorize certain expenses as pre-operative expenses - commencement of business during the year - assessee’s business was ‘set up’ or not...

Allowable business expenses - There is difference between commencement of the business and setting off of the business. All the expenses incurred pre-commencement are to...

Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

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,...

Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

Pre-operative expenses – Genuineness of expenses proved - AO did not follow or apply AS-7 for computing the income and has not commented why AS-2 applied by the...

Capital gain computation - Allowability of transfer expenses [brokerage, air tickets, hotel accommodation receipts, postal charges receipts, conveyance charges, lawyer...

Applicability of Transfer pricing provisions - Transactions with joint venture - transactions between the assessee and IJMII do not fall under section 92B(2) -...

Nature of Interest income - first ground of appeal of the assessee for treating expenses to the amount as revenue expenditure is dismissed. However, the alternative...

Valuation - sale of Gypsum - mere bifurcation of the sale price of the goods in a mutual contract between the parties under a separate bargain or even a common bargain...

Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

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

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...

Transfer pricing adjustment - Berry ratio selected as most appropriate method for determining the ALP - since the assessee had incurred abnormal expenses for specific...

Quick Updates: