Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Page of 4792
Press 'Enter' after typing page number.
121 to 140 of 95833 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT directed the AO/TPO to delete the addition for corporate guarantee commission assessed at 0.5% and sustained the assessee's appeal. The Tribunal rejected the protective adjustment of 0.5% as a risk-mitigation factor, holding that the assessee's advance to its associated enterprise (AE) carrying interest at 1.9%-matching the bank's rate-was consistent with arm's-length principles. The ITAT found the AO/TPO's determination of ALP flawed for failing to apply any prescribed method under s.92C and for not undertaking a benchmarking exercise or valuing the specific services received from the AE; consequently the impugned transfer pricing adjustments were set aside and the appeal allowed.
The ITAT directed the AO/TPO to delete the addition for corporate guarantee commission assessed at 0.5% and sustained the assessee's appeal. The Tribunal rejected the protective adjustment of 0.5% as a risk-mitigation factor, holding that the assessee's advance to its associated enterprise (AE) carrying interest at 1.9%-matching the bank's rate-was consistent with arm's-length principles. The ITAT found the AO/TPO's determination of ALP flawed for failing to apply any prescribed method under s.92C and for not undertaking a benchmarking exercise or valuing the specific services received from the AE; consequently the impugned transfer pricing adjustments were set aside and the appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
