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Income Tax - Highlights / Catch Notes

Home Highlights May 2014 Year 2014 This

Transfer pricing adjustment – Guarantee charges for guarantee to ...

Income Tax

May 28, 2014

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 0.20% can be made - AT

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  1. Transfer pricing adjustment – Indenting transactions - commission percentage from AE transactions should be benchmarked on the basis of commission rate from non-AE...

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  5. TP Adjustment - ‘receipt of counter guarantee commission - providing counter guarantee at the instance of its overseas AE - TPA made in the impugned assessment order...

  6. Transfer pricing adjustment - No interest having been charged by the assessee to the non-AE outstandings, its transaction of outstanding receivables with AE without...

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  8. TP adjustment on account corporate guarantee provided by the assessee to its AE - no transfer pricing adjustment could be made with regard to corporate guarantee issued...

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  10. 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...

 

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