Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
The HC declined to entertain the petition challenging the Tribunal's decision under Section 254(2) regarding TP adjustment for guarantee fees paid to an Associated Enterprise. The Court noted that the Tribunal had decided Ground No.4 in favor of the Assessee based on a precedent from the Gujarat HC [2018] that confirmed a similar ruling for an earlier assessment year (2009-10). The Court determined it would be an academic exercise to evaluate the Tribunal's power to recall its order under Section 254(2) when the HC had already approved similar findings in the previous assessment year, thereby implicitly validating the Tribunal's conclusion rejecting the upward TP adjustment of guarantee fees.
The HC declined to entertain the petition challenging the Tribunal's decision under Section 254(2) regarding TP adjustment for guarantee fees paid to an Associated Enterprise. The Court noted that the Tribunal had decided Ground No.4 in favor of the Assessee based on a precedent from the Gujarat HC [2018] that confirmed a similar ruling for an earlier assessment year (2009-10). The Court determined it would be an academic exercise to evaluate the Tribunal's power to recall its order under Section 254(2) when the HC had already approved similar findings in the previous assessment year, thereby implicitly validating the Tribunal's conclusion rejecting the upward TP adjustment of guarantee fees.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
