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Income Tax - Highlights / Catch Notes

Home Highlights January 2020 Year 2020 This

TP Adjustment - interest free loan given to its associated ...

Income Tax

January 21, 2020

TP Adjustment - interest free loan given to its associated enterprise (AE) - Lower authorities have erred in going by the penal interest stipulation in the loan agreement to the corresponding interest benchmark in the overseas market. - Addition deleted.

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  1. TP Adjustment - Notional interest - interest-free advances extended by the assessee to its AE - In an uncontrolled condition and between persons other than associated...

  2. Transfer pricing adjustment – When the indent/commission transaction with the associated enterprises is to be benchmarked, the same should be done with indent/...

  3. TP upward adjustment on account of interest free loan to AE - The interest cost compared to the amount of gross import of material and export generated by the taxpayer...

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  5. TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

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  7. Transfer pricing adjustment - international transaction relating to acquisition of intangible assets by assessee from its associated enterprise - All the additions...

  8. 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

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  10. 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...

 

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