TPA - it is since the parameters laid down in sub-section (1) ...

Income Tax

July 25, 2016

TPA - it is since the parameters laid down in sub-section (1) are not fulfilled, there is no relationship of AE between assessee-company and JII and therefore, the provisions of chapter X of the Act have no application. In the result, the transfer pricing adjustment made by the TPO is not valid in law. - AT

View Source

← Previous Next →

TPA - it is since the parameters laid down in sub-section (1) ...

Income Tax

July 25, 2016

You may also like:

TDS u/s 195 - software expenses - the arrangement of the assessee company with its AE is of purchase of computer software at agreed price i.e. sale price to the Indian...

Deduction u/s 80IA - Onus is on the assessee to prove strictly that assessee fulfills all the parameters laid down by the statute for claiming the deduction. In the...

TPA - Adjustment of interest for delayed realization of sale from AE - when the assessee is not charging any interest from non AE then there is no case made out by the...

Deduction u/s 10B - ordinarily, what profit the assessee might have expected to arise - AO had not brought on record any material to demonstrate that the assessee...

TDS u/s 195 - withhold tax on the payments made to the MRI company - assessee contended that it is acting as a collection agent on its behalf - Neither the assessee nor...

Disallowance u/s. 2(22)(e) - assessee has received unsecured loan and assessee company from whom it has obtained unsecured loan there were two common directors - Since...

TP adjustment in respect of management fee - When the TPO alleges that the assessee has not received any of the above services, it would indicate that the very...

Depreciation on Car - Assessee has not earned any revenue from hotel business - The assessee company is in existence under the Companies Act and it has to fulfill...

Deduction u/s 80IA - whether assessee fulfilled the condition of sub-Section (4)(i)(b) of Section 80IA? - partnership firm was converted into a company - For the...

TP adjsutment - “AE” investment banking activities - comparable selection - The persistence loss- making company are normally excluded as comparable. As per the...

TDS u/s 194A - TDS on deemed dividend - loan advanced by the assessee company to the other group companies - Even if, the appellant company hold 100% shares in these...

TPA - valid comparable - the accounting period of the comparable company should be the same with that of the assessee-company.

Addition u/s 56(2)(viia) - taking fair market value of buy back of shares by assessee from its holding company a company incorporated in USA - the provisions of section...

Set off of accumulated unabsorbed losses - scheme of amalagamtion conceived - As on 31.03.2013, the assessee company had only 26% of equity shares in the transferor...

Disallowance u/s 36(1)(iii) - claim of interest expenditure - The companies GIL and CNIL are subsidiary companies, which clearly indicates that the investment made by...

Quick Updates: