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Income Tax - Highlights / Catch Notes

Home Highlights December 2015 Year 2015 This

Since the operating profit to cost margin of the appellant at ...

Income Tax

December 23, 2015

Since the operating profit to cost margin of the appellant at 9.26% is higher than the operating profit to cost ratio of the comparable companies at 6.30%, the adjustment made by the AO/TPO/DRP, in relation to international transaction of provision of business support services, is deleted - AT

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  2. 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

  3. Amends Abatement Notification no. 26/2012 ST dated 20-6-2012 - Removes the entry related to Chits in the definition part - Notification

  4. TPA - 'operating profit’ from the international transaction is compared with the operating profit margin of the comparables under the TNMM. Thus the addition based on...

  5. Due date for furnishing of annual returns in FORM GSTR-9, FORM GSTR-9A and reconciliation statement in FORM GSTR-9C for the FY 2017-2018 extended till 30.06.2019.

  6. TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net...

  7. Clarification on Point of Taxation Rules - regarding. - Cir. No. 155/6/ 2012 – ST Dated: April 9, 2012

  8. Assessment u/s 144 -profit margins, could be varied and disturbed only if the profit margins of other assesses engaged in similar business are higher

  9. Transfer pricing adjustment - adjustment in respect of international transaction relating to export of manufactured IC engines by considering the difference in the gross...

  10. Net profit @ 6% on bank deposits made - authorities below shall apply profit rate of 5% for the purpose of computing part addition as was directed in assessment year 2008-09 - AT

 

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