TP Adjustment - corporate guarantee given by the assessee ...

Income Tax

August 4, 2023

TP Adjustment - corporate guarantee given by the assessee company to its AEs - the corporate guarantee commission is an international transaction and should be charged @ 0.50% on the corporate guarantee amount given to the AEs - AT

View Source

← Previous Next →

TP Adjustment - corporate guarantee given by the assessee ...

Income Tax

August 4, 2023

You may also like:

TP Adjustment - Arm's length price of the corporate guarantee fee - Lower authorities have also included a letter of comfort as part of corporate guarantee - We reject...

TP adjustment on account corporate guarantee provided by the assessee to its AE - no transfer pricing adjustment could be made with regard to corporate guarantee issued...

TP Adjustment - associated enterprises (AEs) - Business advances cannot be construed as loan advanced to the assessee company. Once the same is excluded and the loans...

Demand of service tax - providing services without consideration (free) to its associate companies - activity of giving corporate guarantee - The Show Cause Notice...

TP Adjustment - TP Adjustment on corporate guarantee - As it is a case of holding company and subsidiary company transaction, we do not think any reason to consider the...

TP adjustment commission on letter of credit - international transaction or not? - CIT (A) appreciated the difference between corporate guarantee and Letter of Comfort....

TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...

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...

TP Adjustment - Addition on account of corporate guarantee - International transaction - guarantee fees / commission @ 0.35% will meet the arm’s length criteria in the...

TP Adjustment - assessee has issued the corporate guarantee on behalf of AE’s - interest saved approach - The ITAT decided in favor of the assessee, directing the AO to...

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

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

TP Adjustment - Addition of Corporate Guarantee - Matter restored before the AO with the direction that, he will first ascertain the amount of expenditure actually...

TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...

TP Adjustment - adjustment of brokerage income - assessee also filed submission before the TPO providing detailed explanation with regard to the differences in services...

Quick Updates: