Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights August 2021 Year 2021 This

TP Adjustment - corporate guarantee forms an international ...

Income Tax

August 31, 2021

TP Adjustment - corporate guarantee forms an international transaction or not? - Explanation to Section 92B inserted vide the Finance Act, 2012 with retrospective effect from 01-04-2002 also includes a corporate guarantee. We thus hold that the tribunal’s all foregoing orders must make way for higher wisdom and decline the assessee’s first and foremost legal plea. - AT

View Source

 


 

You may also like:

  1. TPA - even if it could be treated as a corporate guarantee for benchmarking purposes, the corporate guarantee does not constitute an international transaction under...

  2. 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...

  3. 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...

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

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

  6. Transfer pricing adjustment - applicability of CUP to a single combined international transaction of Import of Crystal goods and Crystal components, cannot be considered...

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

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

  9. TP Adjustment in respect of extension of performance/ corporate guarantee - Even if it is reckoned as international transaction, then also on FAR analysis and looking to...

  10. Transfer pricing - the issuance of corporate guarantees is covered by the residuary clause of the definition under section 92B of the Act but since such issuance of...

 

Quick Updates:Latest Updates