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Income Tax - Highlights / Catch Notes

Home Highlights April 2017 Year 2017 This

TPA - corporate guarantee commission fee which is to be ...

Income Tax

April 27, 2017

TPA - corporate guarantee commission fee which is to be recovered from AE should be @ 0.50% which would meet the arms length requirement. - AT

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  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 - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

  3. Transfer pricing adjustment deleted - the comparables adopted by the assessee are uncontrolled parties and can be considered for the purpose of determining the Arms'...

  4. Jurisdiction of Transfer Pricing Officer - Suo motu, TPO cannot take cognizance of any international transaction for suggesting adjustment in the arm’ s length price,...

  5. 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...

  6. TP Adjustment - arm’s length price of interest on short term loan granted to the AE - The fact that the assessee has provided a short term loan only for a period of 15...

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

  8. TP - Arm's length price - CBDT instruction does not restrict the powers of the AO from making references to the Transfer Pricing Officer after 30th June 2003

  9. Transfer pricing adjustment - No interest having been charged by the assessee to the non-AE outstandings, its transaction of outstanding receivables with AE without...

  10. TP Adjustment to the licence fees paid for time and billing software - Determination of arm's length price at Nil in grounds 1 & 2 and at Rs. 50 lakhs on ad hoc basis in...

 

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