Tag Archives: IN THE ITAT AHMEDABAD BENCH

Delayed Receivables Subsumed Under TNMM and Working Capital Adjustment Cannot Face Separate Notional Interest Imposition Issue Whether a separate Transfer Pricing (TP) adjustment by imputing notional interest on delayed trade receivables from Associated Enterprises (AEs) is legally sustainable when the transaction has already been benchmarked under the Transactional Net Margin Method (TNMM) and a working… Read More »

Assessee wins corporate guarantee, R&D, and registration claims; medical freebies and late welfare dues disallowed. Issue Whether the various additions and disallowances made by the Assessing Officer (AO) for Assessment Year 2013-14—concerning corporate guarantees, interest on borrowings, weighted R&D deductions, product registration expenses, exempt income disallowances (under regular and MAT provisions), foreign exchange hedging losses,… Read More »

Consistency in Transfer Pricing methodology and prevention of double taxation on reversed provisions bind the Assessing Officer. Consistency in Transfer Pricing methodology and prevention of double taxation on reversed provisions bind the Assessing Officer. Issue Whether the Transactional Net Margin Method (TNMM) at the entity level remains the most appropriate method for benchmarking international transactions… Read More »