TP adjustment - Recharacterising the compulsorily convertible ...

Income Tax

December 4, 2020

TP adjustment - Recharacterising the compulsorily convertible debentures (`CCDs') as equity shares - till the date of conversion, for allowability of interest u/s 36 (1) (iii) of Income tax Act also, such CCDs are to be considered as Debt only and interest thereon has to be allowed and it cannot be disallowed by saying that CCDs are equity and not debt. - AT

View Source

← Previous Next →

TP adjustment - Recharacterising the compulsorily convertible ...

Income Tax

December 4, 2020

You may also like:

TPA - international transaction - any further adjustment only on the basis of the outstanding receivables would have distorted the picture and recharacterised the transaction

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

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...

Transfer pricing adjustment - the addition of ₹ 15.18 lac on account of interest on the deemed loan due to under-receipt of share premium cannot be sustained - AT

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

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...

Transfer Pricing Adjustment - Transfer Pricing Regulations do not contemplate taking into account future data for the purpose of bench marking - AT

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

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

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

Quick Updates: