Home Highlights August 2017 Year 2017 This

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1. TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

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

3. TP adjustment - AMP expenses - the existence of an international transaction will have to be established de hors the BLT, the burden is on the Revenue to first show the...

4. Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

5. Transfer pricing adjustment - arm‘s length pricing of international transactions - Advertising / Marketing and Promotion Expenses - international transaction - Domestic...

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

7. Transfer Pricing adjustment - Revenue authorities were fully justified in treating the transaction of brand building an international transaction in the facts and...

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 - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

10. Validity of order passed u/s 92CA - Transfer Pricing - Since the ld. TPO order has been passed on 30/10/2015 which is clearly barred by limitation by one day by virtue...

11. TP Adjustment - Addition of international transaction related to the demerger - The High court identified a jurisdictional overreach by the AO, who made an adjustment...

12. TP adjustment on account of back-to-back counter bank guarantee - TPO, by considering the rate charged by Bank of Baroda for issuance of guarantee against 100% counter...

13. 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...

14. TP Adjustment - international transaction - in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur AMP expenses,...

15. With the passage of time where India is becoming a global commercial hub with the advent of Multinational Companies new transfer pricing issues are thrown up and keeping...