Tag: alp
No penalty u/s 271G if no adjustment made in Arm’s Length Price – ITAT In a recent judgment, the ITAT has upheld that no penalty under section 271G can be levied if no adjustment made in Arm’s Length Price ABCAUS Case Law Citation:ABCAUS 3845 (2024) (01) ITAT Important …
CBDT notifies tolerance/variation limit between arm’s length price u/s 92C and the actual price for international/specified domestic transaction for AY 2020-2021 MINISTRY OF FINANCE(Department of Revenue) Notification No. 83/2020 New Delhi, the 19th October, 2020 S.O. 3660(E).—In exercise of the powers conferred by the third proviso to sub-section …
ALP determined in good faith and with due diligence by assessee was not liable to penalty u/s 271(1)(c) ABCAUS Case Law Citation:ABCAUS 3310 (2020) (05) ITAT Important case law relied upon by the parties:Dharmendra Textile Processors 295 ITR 244Zoom Communication Pvt. Ltd. 327 ITR 510MAK Data Pvt. Ltd. …
Transfer pricing adjustment without reference to TPO. Supreme Court upholds that AO breached mandatory Instruction but restored appeal to AO ABCAUS Case Law Citation:ABCAUS 3119 (2019) (08) SC Important case law relied upon by the parties: The instant Appeal by Special Leave was made by the Revenue to …
Arm’s length rate of interest is the rate prevalent in country of AEs where loan is received/consumed and not the country whose enterprise advances loans ABCAUS Case Law Citation: ABCAUS 3063 (2019) (07) ITAT Important Case Laws Cited/relied upon by the parties: CIT Vs. Tata Autocomp Systems Ltd. …
Permitted ALP variation in wholesale trading-others us 92C in international-specified domestic transaction for AY 2017-18 2018-19 MINISTRY OF FINANCE (Department of Revenue) Notification No. 50/2017 New Delhi, the 9th June, 2017 S.O. 1866(E).—In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C …
MINISTRY OF FINANCE (Department of Revenue) NOTIFICATION New Delhi, the 14th July, 2016 S. O. 2425(E).—In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act,1961 (43 of 1961), read with proviso to sub-rule (7) of rule 10CA of …