Tag: Arms length price
Arm’s Length Price allowable variation limits u/s 92C notified for AY 2023-24 MINISTRY OF FINANCE(Department of Revenue) Notification No. 46/2023 New Delhi, the 26th June, 2023 INCOME-TAX S.O. 2777(E).—In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act, …
There is no absolute proposition of law that arm’s length price determined by ITAT is final and cannot be subjected to judicial scrutiny in an appeal under Section 260A of the Income Tax Act. ABCAUS Case Law Citation:ABCAUS 3710 (2023) (04) SC Important Case Laws relied upon :PCIT …
Arms length price us 92C variation in wholesale trading up to 1% and 3 % in other cases to be deemed ALP for AY 2022-23 MINISTRY OF FINANCE(Department of Revenue) Notification No. 70/2022 New Delhi, the 28th June, 2022 S.O. 2928(E).—In exercise of the powers conferred by the …
Deemed arm’s length price in case of variation between price determined u/s 92C for international transaction or specified domestic transaction for AY 2021-22 MINISTRY OF FINANCE(Department of Revenue) Notification No. 124/2021 New Delhi, the 29th October, 2021 (INCOME TAX) S.O. 4586(E).—In exercise of the powers conferred by the …
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. …
Arms Length Price of intra group management fee paid determined Nil by TPO upheld as there was no evidence on record to prove rendition of services. ABCAUS Case Law Citation: ABCAUS 3002 (2019) (06) ITAT Important Case Laws Cited/relied upon by the parties: 3M India Ltd vs. Addl. …
Reopening for overlooking transactions with associated enterprises and not referring them to TPO for computation of at arms’ length income was not change of opinion – High Court ABCAUS Case Law Citation: ABCAUS 2130 (2017) (11) HC The petitioner company was incorporated in the United Kingdom and …
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 …