Availability of +-5% benefit in determining the ALP - NIL ALP of ...

+5% Benefit for Arm's Length Price on Management Fees Applicable for AY 2010-11 Per Section 92C(2) Amendment.

June 11, 2019

Case Laws Income Tax AT

Availability of +-5% benefit in determining the ALP - NIL ALP of the international transaction of Payment of management fees - Second proviso to section 92C(2) substituted by the Finance (No.2) Act, 2009 w.e.f. 01-10-2009 - it is overt that even for the assessment year, namely, 2010-11, the benefit of the second proviso would be available by virtue of the Explanation given at the end of Section 92C(2)

View Source

← Previous Next →

Availability of +-5% benefit in determining the ALP - NIL ALP of ...

+5% Benefit for Arm's Length Price on Management Fees Applicable for AY 2010-11 Per Section 92C(2) Amendment.

June 11, 2019

Case Laws Income Tax AT

You may also like:

TP Adjustment - determination of Arm's Length Price - intra group services transactions as Cross-charges - Documents submitted by the assessee do not conclusively...

TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's Length Price is required to be determined for a transaction with specified persons in section 40A(2)(b)...

HC affirmed tax authority's adjustment of AY 2010-11 refund against pre-existing tax liabilities of corporate debtor. Resolution applicant's claim to refund rejected on...

The ITAT Ahmedabad addressed Transfer Pricing (TP) adjustments, focusing on royalty, management fees, and IT allocation costs. The tribunal upheld the use of the...

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...

Foreign Exchange Management (Guarantees) (Amendment) Regulations, 2012 – Amendment in Regulations 2 And 4 - Notification

TP Adjustment - Disallowance on professional fee u/s 40A(2) and alternatively u/s 37 - the A.O. has erred in invoking the provisions of section 40A(2) of the I.T.Act to...

FEMA (Transfer or Issue Of Security By A Person Resident Outside India) - Sixth Amendment – Amendment In Regulations 2, 5, 10, 12 And Schedules 1, 2, 5, 6 & 7 - Notification

Revision u/s 263 by CIT - disallowance of exemption claimed in respect of accumulation of income u/s 11(2) - insofar as the impugned assessment year is concerned, there...

Addition u/s 56 - transaction in shares - adequate consideration - Section 56(2)(viia) was brought in the statute book only w.e.f. 1st June, 2010 i.e. for AY 2011-12 -...

Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

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...

Rectification u/s 154 - Exemption u/s 11(2) - Accumulation of income - The Appellate Tribunal found merit in the appellant's contention regarding the amount to be...

Section 14A disallowance restricted to 2% of exempt income due to inapplicability of Rule 8D for the relevant assessment year. TDS disallowance u/s 40(a)(ia) upheld for...

Disallowance of sales tax liability - Prior-period item - the year under appeal is AY 2013-14. The alleged amount pertains to AY 2005-06 and AY 2010-11 and such...

Quick Updates: