Transfer Pricing

Blog, News, Transfer Pricing

January 4, 2022

Omission of clause (i) of sec. 92BA is retrospective though it stood omitted w.e.f. 1-4-2017: ITAT

Case Details: Ammann India (P.) … Continue reading “Omission of clause (i) of sec. 92BA is retrospective though it stood omitted w.e.f. 1-4-2017: ITAT”

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December 28, 2021

South Africa releases model legislation to introduce Advance Pricing Agreement Programme

News, dated 27-12-2021 In keeping … Continue reading “South Africa releases model legislation to introduce Advance Pricing Agreement Programme”

Blog, News, Transfer Pricing

December 6, 2021

No separate TP adjustment is needed for interest on receivables if working capital adjustment is made: ITAT

Case Details: ERM India (P.) … Continue reading “No separate TP adjustment is needed for interest on receivables if working capital adjustment is made: ITAT”

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November 30, 2021

No TP adjustment if assessee was availing more credit period vis a vis credit period it granted to its AEs : ITAT

Case Details: Coim India (P.) … Continue reading “No TP adjustment if assessee was availing more credit period vis a vis credit period it granted to its AEs : ITAT”

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November 24, 2021

No TP adjustment for ‘performance guarantee’ as contractual revenue would belong to guarantor if guarantee was invoked

Case Details: DCIT v. KEC … Continue reading “No TP adjustment for ‘performance guarantee’ as contractual revenue would belong to guarantor if guarantee was invoked”

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November 8, 2021

CBDT notifies tolerance limit under transfer pricing for Assessment Year 2021-22

Notification No. 124/2021, dated 29-10-2021 … Continue reading “CBDT notifies tolerance limit under transfer pricing for Assessment Year 2021-22”

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October 25, 2021

No TP adjustment if amount received in advance was far outweighed amount received late from AE: HC

Case Details: PCIT v. Mckinsey … Continue reading “No TP adjustment if amount received in advance was far outweighed amount received late from AE: HC”

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October 25, 2021

Practical experience on TP Assessment

Gaurav Jain & Drashti Sanghavi … Continue reading “Practical experience on TP Assessment”

Blog, News, Transfer Pricing

September 2, 2021

ITAT grants relief to ‘Times Group’; no ALP adjustment on interest free debt funding to overseas-SPV

Case details: Bennett Coleman & … Continue reading “ITAT grants relief to ‘Times Group’; no ALP adjustment on interest free debt funding to overseas-SPV”

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August 25, 2021

AO isn’t required to pass draft assessment order while considering case remanded back by tribunal: HC

Case details: Enfinity Solar Solutions … Continue reading “AO isn’t required to pass draft assessment order while considering case remanded back by tribunal: HC”