raised final 92ca macrotech passed case ao gland title transfer tribunal assessee constable hormones direct court ahmedabad assessees loc deleted tsh students interest determining pricingassessees jntucea placements days given objections

Articles for Tpo, search results for alp

Ahmedabad ITAT Explains Difference Between Letter Of Credit From Corporate Guarantee
7 months, 3 weeks ago

Ahmedabad ITAT Explains Difference Between Letter Of Credit From Corporate Guarantee

Live Law  

While upholding ALP adjustment on LOC in case of Axis Bank, the Ahmedabad ITAT rules on difference between letter of comfort and guarantee commission. With respect to LOC being equated to bank guarantees, the Bench comprising Annapurna Gupta and T.R Senthil explains that bank guarantee is a kind of guarantee from a lending organization to cover a debtor's liabilities if …

Bank Case Bench Loc Itat Guarantee Boi
AO Is Not Clothed With Powers To Ascertain ALP Of Any International Transaction: Delhi High Court
8 months, 2 weeks ago

AO Is Not Clothed With Powers To Ascertain ALP Of Any International Transaction: Delhi High Court

Live Law  

The Delhi High Court has held that AO is not clothed with the powers to ascertain the Arm's Length Price of any international transaction.The bench of Justice Yashwant Varma and Justice Purushaindra Kumar Kaurav has observed that the AO is not clothed with the powers to ascertain the ALP of any international transaction that is selected based on the transfer …

International Court Transfer Delhi High Court Order Income Pricing
No ALP On AMP Expense Is Warranted In Absence Of Agreement Between Assessee And Its AE For Service W.r.t Brand Promotion Activity: Chennai ITAT
9 months, 1 week ago

No ALP On AMP Expense Is Warranted In Absence Of Agreement Between Assessee And Its AE For Service W.r.t Brand Promotion Activity: Chennai ITAT

Live Law  

The Chennai ITAT deleted the ALP adjustment made towards The Bench comprising Mahavir Singh and Manoj Kumar Aggarwal on identical issue, noted that the Coordinate bench in assessee's own cases for AYs 2012-13 and 2016-17 deleted the adjustment holding that there was no formal agreement or arrangement between assessee and its AEs for rendering of service w.r.t alleged brand promotion …

Brand Bench Hyundai Itat Assessee Expense Its Ae
ITAT Dirests ALP Computation Towards Guarantee Commission @ 0.3523% In Case Of Macrotech Developers
1 year, 1 month ago

ITAT Dirests ALP Computation Towards Guarantee Commission @ 0.3523% In Case Of Macrotech Developers

Live Law  

The Mumbai Bench of Income Tax Appellate Tribunal has directed the ALP Computation Towards Guarantee Commission at a rate of 0.3523% in the case of Macrotech Developers.The bench of Kuldip Singh and Padmavathy S. has observed that the rate of guarantee commission is required to be determined on the basis of the credit rating of the issuer company. The Mumbai …

Case Commission Rate Given Itat Guarantee Assessee
ALP Of The ESOP Expenses Cannot Be Taken As ‘Nil’: ITAT
1 year, 2 months ago

ALP Of The ESOP Expenses Cannot Be Taken As ‘Nil’: ITAT

Live Law  

The Mumbai Bench of Income Tax Appellate Tribunal has held that the arm's-length price of the employee stock option plan expenses cannot be taken as ‘Nil’.The bench of Rahul Chaudhary and S. Rifaur Rahman has observed that the transfer pricing addition of INR 26,53,078 is, therefore, set aside, and the TPO/Assessing Officer is. The Mumbai Bench of Income Tax Appellate …

Expenses Employee Inr Itat Appellant Esop Tpo