Chargeability of Royalty from Associated Enterprises (AEs) - ...

Income Tax

January 29, 2022

Chargeability of Royalty from Associated Enterprises (AEs) - International transaction as contemplated u/s 92B - The facts in the present assessment is also similar and no distinguishing facts were pointed out by the Ld. DR or the Ld. AR, therefore, the finding of the CIT(A) that royalty @ 2% is to be charged from AE, appears to be not correct. Therefore, following the earlier years order by the Tribunal, we are restricting the said royalty to 0.75% in case of AE - AT

View Source

← Previous Next →

Chargeability of Royalty from Associated Enterprises (AEs) - ...

Income Tax

January 29, 2022

You may also like:

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

Corporate Guarantee or Letter of Comfort given by the assessee to its Associate Enterprise does not involve any cost to the assessee, therefore, it was outside the ambit...

TP Adjustment - Receipt of royalty income from its associated enterprises - when the approach adopted by the assessee is found to be acceptable, the adjustment...

Rate of tax - royalty income earned by the assessee from its Indian Associated Enterprises, pursuant to an agreement dated 01-04-2008, should be charged to tax at 10.5060%.

TP Adjustment - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of...

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

TP Adjustment - goods sold to Associated Enterprises (AEs) - NP Determination - The TPO has not given any reason as to why he did not consider above said two expenses...

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from...

TP Adjustment - As per the provisions of aforesaid Rule, the ‘other method’ shall be the method which takes into account the price which has been or would have been...

Quick Updates: