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 2023 Year 2023 This

TP Adjustment - ALP of the services provided by the AE (China) ...

Income Tax

August 18, 2023

TP Adjustment - ALP of the services provided by the AE (China) to the assessee - eligibility of benefit test - the adjustment made by the TPO on the basis that no services were received becomes erroneous. Hence, TPO is directed to delete the adjustment - AT

View Source

 


 

You may also like:

  1. TP Adjustment - secondment of employees by Assessee to its AE - the benchmarking done by the TPO by applying the same rate of thirty party placement agency is not...

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

  3. Transfer pricing adjustments - Location Savings and Imputation of mark-up on pass through costs - this intra-group services rendered by the assessee to the parent...

  4. TP Adjustment - ALP determination - intra-group services - TPO cannot stand in judgment on what benefits the assessee has derived from the services and assessee's...

  5. TP Adjustment - ALP determination - depreciation - operating cost - since the assets are used by the assessee with respect to the services provided to AE and hence the...

  6. TP adjustment - ALP of management service fees at Nil - receipt of service from other group companies not doubted - The authorities below cannot sit in judgment over the...

  7. TP Adjustment - Upward adjustment of Arm’s Length Price in respect of Management Services - These services are not in the nature of stewardship or shareholder activity....

  8. 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...

  9. TP Adjustment - MAM Adjustment - ALP adjustment -In TNMM what is to be seen is the functional comparability and not the product comparability. Further, it is observed...

  10. TP Adjustment - ALP adjustment qua receipt of management services - the assessee has already filed its detailed paper book in the nature of supportive evidence...

  11. TP adjustment against payment to AE for Software charges - The charges have been paid pursuant to the agreement and the assessee has already placed on record third part...

  12. TP Adjustment - arm’s length price of interest on short term loan granted to the AE - The fact that the assessee has provided a short term loan only for a period of 15...

  13. TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result...

  14. Adjustment of excess service tax paid with subsequent service tax liability - case of Revenue is that Rule 6 (3) of Service Tax Rules, 1994 do not provide for such...

  15. TP adjustment - Intragroup services filed by the assessee from its AE - Either way when the Revenue seeks to disturb the Most Appropriate Method adopted by the assessee,...

 

Quick Updates:Latest Updates