The Tribunal addressed various issues related to transfer ...

Tribunal Rules on Transfer Pricing: Comparables Upheld, Interest Capped at LIBOR +250bps, Loss Set-Off Claims Dismissed.

September 25, 2024

Case Laws Income Tax AT

The Tribunal addressed various issues related to transfer pricing adjustments, including the selection of comparables, interest on trade receivables, and set-off of losses. Regarding comparables, the Tribunal upheld the inclusion of E-Infochips Bangalore Ltd. and Mindtree, rejecting the assessee's objections. However, it excluded Persistent Systems Ltd. due to the absence of inventory related to software products. Concerning interest on trade receivables, the Tribunal followed the DRP's decision to restrict interest to LIBOR plus 250 basis points, despite contrary Tribunal precedents, as the Revenue did not appeal the DRP's order. The Tribunal dismissed the assessee's ground regarding set-off of losses between units, citing the lack of objection before the DRP and the restriction u/s 92C(4) proviso. The order provides clarity on the Tribunal's approach to various transfer pricing issues.

View Source

← Previous Next →

The Tribunal addressed various issues related to transfer ...

Tribunal Rules on Transfer Pricing: Comparables Upheld, Interest Capped at LIBOR +250bps, Loss Set-Off Claims Dismissed.

September 25, 2024

Case Laws Income Tax AT

You may also like:

ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely...

ITAT adjudicated transfer pricing dispute regarding comparable company selection. The tribunal determined the Arm's Length Price (ALP) computation by the Transfer...

ITAT adjudicated a transfer pricing dispute involving comparability analysis and interest computation on outstanding receivables. The tribunal rejected certain...

The ITAT Ahmedabad addressed Transfer Pricing (TP) adjustments, focusing on royalty, management fees, and IT allocation costs. The tribunal upheld the use of the...

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

The Appellate Tribunal addressed various Transfer Pricing (TP) issues. Regarding software services, the Tribunal upheld the selection of comparables by the assessee over...

ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal upheld the TPO's rejection of the assessee's transfer pricing study,...

The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

ITAT adjudicated transfer pricing dispute regarding software development services benchmarking. The Tribunal comprehensively examined functional comparability, rejecting...

Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

ITAT determined that for benchmarking outstanding receivables from Associated Enterprises (AEs), the applicable interest rate should be LIBOR, not domestic prime lending...

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 - Eligible International Transaction - safe harbor rules - The court examined the eligibility of international transactions under Rule 10TC of the Income...

ITAT adjudicated transfer pricing dispute, directing significant procedural adjustments. The tribunal found computational discrepancies in Arm's Length Price (ALP),...

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: