Transfer Pricing Adjustments - The Tribunal reaffirmed the ...

Income Tax

March 28, 2024

Transfer Pricing Adjustments - The Tribunal reaffirmed the primacy of the TNMM over CUP for benchmarking certain types of transactions, especially when comparable data for CUP is not readily available or applicable. - The ruling emphasized the reduced rate of taxation on interest income from foreign currency loans under specific conditions, thereby clarifying the applicability of section 115A over normal tax rates. - The allowance of deductions under section 44C was confirmed, highlighting the importance of adhering to the statutory limits and maintaining proper documentation to support such claims. - Lastly, the Tribunal's interpretation of the India-Canada DTAA in the context of taxability of interest on income tax refunds signals a broader understanding of DTAAs' provisions, particularly regarding the exemptions available to non-residents.

View Source

← Previous Next →

Transfer Pricing Adjustments - The Tribunal reaffirmed the ...

Income Tax

March 28, 2024

You may also like:

Transfer pricing adjustment deleted - the comparables adopted by the assessee are uncontrolled parties and can be considered for the purpose of determining the Arms'...

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

Transfer pricing adjustment – Indenting transactions - commission percentage from AE transactions should be benchmarked on the basis of commission rate from non-AE...

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 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...

TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net...

Transfer pricing adjustment - most appropriate method - CUP method was not correct method - AO directed to apply TNMM method to benchmark the international transactions...

Transfer Pricing Adjustments - downward adjustment made by the TPO and enhanced by the CIT(A) - adoption of the Transactional Net Margin Method (TNMM) over other methods...

Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The...

The Tribunal meticulously analyzed each issue, heavily relying on precedent ITAT decisions and the specifics of the case presented. For the major contentious points,...

Quick Updates: