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 May 2016 Year 2016 This

Transfer pricing adjustment towards notional guarantee ...


Transfer Pricing Adjustment: 0.5% Arm's Length Price Set for Notional Guarantee Commission to Associated Enterprises.

May 5, 2016

Case Laws     Income Tax     AT

Transfer pricing adjustment towards notional guarantee commission chargeable for the guarantee extended to its associated enterprises - commission chargeable for guarantee commission by the assessee to its associated enterprises should be taken at 0.5 per cent. as the arm's length price - AT

View Source

 


 

You may also like:

  1. The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

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

  3. The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

  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...

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

  7. 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...

  8. Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

  9. Transfer pricing adjustment - No need for provision of +/- 5% range for CPM of the arm's-length price as there are no comparable prices in the instant case providing a...

  10. Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The...

  11. 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...

  12. ITAT adjudicated transfer pricing dispute regarding comparable company selection. The tribunal determined the Arm's Length Price (ALP) computation by the Transfer...

  13. The High Court upheld the Income Tax Appellate Tribunal's (ITAT) decision regarding the applicability of Section 92(3) in determining the arm's length price for...

  14. Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

  15. ITAT remanded the case to the AO for compliance with DRP's directive regarding transfer pricing adjustment. The tribunal acknowledged the DR's concession that the AO had...

 

Quick Updates:Latest Updates