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Income Tax - Highlights / Catch Notes

Home Highlights January 2020 Year 2020 This

TP Adjustment - application for early hearing and stay ...

Income Tax

January 15, 2020

TP Adjustment - application for early hearing and stay application was rejected by the ITAT - Matter restored before the ITAT - Till then, no coercive steps be taken against the appellant, for recovery of the tax demand.

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  1. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

  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 - royalty payment - rejecting the entire payment without there being any analysis cannot be accepted - AT

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  5. TPA - determination of ALP - TP adjustment by applying Bright Line Test (BLT) is not sustainable on protective basis having no statutory mandate.

  6. Transfer pricing adjustment – export to associated enterprises of spares and components required for the purpose of servicing of vehicles sold by assessee - the...

  7. 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...

  8. Transfer Pricing - adjustment to ALP - addition - consideration of transactions both with AEs and Non-AEs for the purpose of recommending adjustment - AT

  9. TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned...

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