Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights December 2015 Year 2015 This

Transfer pricing adjustment - When assessee is not able to bring ...

Income Tax

December 18, 2015

Transfer pricing adjustment - When assessee is not able to bring on record anything to show any services to have been rendered by AE to it and there are no documentations to show any services to have been received from AE, in our opinion it will be fair conclusion that no services were in fact rendered by AEs to the assessee. - AT

View Source

 


 

You may also like:

  1. 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...

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

  3. 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...

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

  5. 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...

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

  7. TP adjustment in Distribution activity, described as ESAS - ALP and the consequential transfer pricing adjustment are contemplated only in respect of the international...

  8. 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

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

  10. TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not...

 

Quick Updates:Latest Updates