Transfer pricing adjustment - the addition of ₹ 15.18 lac ...

Tax Tribunal Rules Transfer Pricing Adjustment for Deemed Loan Interest on Share Premium as Unsustainable.

September 24, 2015

Case Laws Income Tax AT

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

View Source

← Previous Next →

Transfer pricing adjustment - the addition of ₹ 15.18 lac ...

Tax Tribunal Rules Transfer Pricing Adjustment for Deemed Loan Interest on Share Premium as Unsustainable.

September 24, 2015

Case Laws Income Tax AT

You may also like:

Deemed dividend u/s 2(22)(e) is not taxable in the hands of the assessee company if it is not a shareholder in the companies that extended loans. It is chargeable to tax...

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...

Adjustment of excess service tax paid with subsequent service tax liability - case of Revenue is that Rule 6 (3) of Service Tax Rules, 1994 do not provide for such...

ITAT determined that NFAC improperly exercised jurisdiction in transfer pricing appeal cases. The tribunal found that CIT(A) at NFAC erroneously assumed jurisdiction...

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely...

TP Adjustment - Eligible International Transaction - safe harbor rules - The court examined the eligibility of international transactions under Rule 10TC of the Income...

Transfer Pricing Adjustment - Adjustment on account of notional interest on the receivables - when the assessee is having their own funds and not paying interest on any...

Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The...

Capital gain on sale of shares - market price or agreed price - transfer of shares by obtaining interest free loans for a long tenure coupled with call option agreements...

Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment...

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

HC determined that AMP expenditure does not constitute a separate international transaction requiring transfer pricing adjustment. The Tribunal consistently applied...

ITAT adjudicated transfer pricing dispute, directing significant procedural adjustments. The tribunal found computational discrepancies in Arm's Length Price (ALP),...

Quick Updates: