Tag: Transfer Pricing
ICAI Revised Guidance Note on Transfer Pricing Report Under Section 92E of the Income-Tax Act 1961 based on law as amended by Finance Act, 2020 GUIDANCE NOTE ON REPORT UNDER SECTION 92E OF THE INCOME-TAX ACT, 1961 (TRANSFER PRICING) (Revised Seventh Edition 2020) The ICAI has issued the …
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. …
Guarantee does not amount to an international transaction under section 92B of the Income Tax Act. ITAT ABCAUS Case Law Citation:ABCAUS 3162 (2019) (10) ITAT Important case law relied upon by the parties:M/s Suzlon Energy Ltd.-vs-ACIT (2017) 188 TTJ 278Micro Ink Ltd Vs ACIT .Siro Clinpharm Pvt Ltd …
CBDT notifies tolerance range for wholesale trading and other cases for transfer pricing for variation between arm’s length price u/s 92C Tolerance range for transfer pricing MINISTRY OF FINANCE(Department of Revenue)New Delhi Notification No. 64/2019- Income Tax Dated: 13th September, 2019 S.O. 3272(E).—In exercise of the powers conferred by …
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 …
Non profit company not a comparable for Transfer Pricing. ITAT directed AO to exclude it from the list of comparables to benchmark international transaction. ABCAUS Case Law Citation:ABCAUS 3112 (2019) (08) ITAT The appellant assessee was is a subsidiary of the parent company which operated travel website under …
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. …
AO not required to issue draft rectification order for assessment completed u/s 144C. Only a proposed “order of assessment” can be challenged before DRP ABCAUS Case Law Citation:ABCAUS 3014 (2019) (06) ITAT Important Case Laws Cited/relied upon by the parties:CIT Vs C Sam India Pvt Ltd Dimension Data …
Draft Assessment order u/s 144C with demand and penalty notice is illegal as it partakes the character of final assessment order – ITAT ABCAUS Case Law Citation: ABCAUS 3013 (2019) (06) ITAT Important Case Laws Cited/relied upon by the parties: Pr. CIT Vs. Lionbridge Technologies Pvt. Ltd. International …
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. …