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 December 2021 Year 2021 This

Upward TP adjustment on account of reimbursement of expenses - ...

Income Tax

December 6, 2021

Upward TP adjustment on account of reimbursement of expenses - The expenses in question were thus clearly for the purpose of the business of the assessee, and deserved to be allowed in full. The TPO should not have ventured into the job of the AO, but that technicality apart, even on merits, entire related expenses, which have been wrongly disallowed by making an ALP- something clearly contrary to the scheme of the Act, these expenses were fully admissible for deduction. - AT

View Source

 


 

You may also like:

  1. TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

  2. Penalty u/s 271(1)(c) - TP Adjustment - it is a debatable issue whether reimbursement of expenses qualifies as FTS and there are various decisions which have held that...

  3. TP adjustment on account of Travel expenses - when the entire expenditure was incurred for hotel stay and travel of both Mr. Stan Wojicierczk and Mr. Raj Lakhani then...

  4. TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

  5. TP adjustment - upward adjustment in imputing notional interest on the outstanding overdue receivables from Associated Enterprises - working capital adjustments on the...

  6. TP Adjustment - AMP expenses by applying bright line test on protective basis - TP adjustment amounting by applying BLT is not sustainable on protective basis having no...

  7. TP Adjustment - Recovery of expenses represent expenses incurred by the assessee company on behalf of AE towards Bid bond expenses. These expenses were also recovered by...

  8. TP Adjustment - international transaction - in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur AMP expenses,...

  9. TP Adjustment - when TNMM method has been applied as most appropriate method it could take care of all notional interest costs wherever it could be applied and there...

  10. Transfer Pricing Adjustments on Corporate Guarantee Charges, Interest on Optionally Convertible Loans (OCL), and Reimbursement of Expenses. - The Tribunal found that...

  11. TP Adjustment - apportioning the expenses of assessee’s affiliates - Also noted that the assessee has received certain services from its AE which has been treated by the...

  12. TP Adjustment - Addition as ‘Fees for Technical Services’ ignoring the assessee’s contention that it was purely reimbursement received for Construction and Management...

  13. TP Adjustment - adjustment on account of AMP - we cannot infer the existence of international transactions qua AMP expenses between taxpayer and AE beyond the...

  14. TP adjustment - TPO while working out the operating cost has made an addition of reimbursement received on account of advertisement and warranty - it is apparent that...

  15. TP Adjustment - upward adjustment under the provisions of section 92 - ALP determination - The amount of depreciation claimed by the assessee in the ratio of turnover...

 

Quick Updates:Latest Updates