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Impact Of Working Capital Adjustment On Outstanding Trade Receivable Must Be Verified Before Making ALP Adjustment Qua Notional Interest: Ahmedabad ITAT

The Ahmedabad ITAT remitted the issue of transfer pricing adjustment regarding interest on overdue trade receivables in case of entity engaged in manufacturing of pharmaceutical products, while.

Parin shahEnterprises aesInternational transactionSuchitra kambleJudicial memberWaseem ahmedAccountant memberTransfer pricing officerLength priceTransaction net margin method

Mitsubishi Corporation Not Liable To Deduct TDS On Sum Which Was Not Chargeable To Tax In India: Delhi High Court

The Delhi High Court has held that the assessee, Mitsubishi Corporation, is not liable to deduct TDS under Section 195(1) of the Income Tax Act where the sum paid was not chargeable to tax in.

United statesJustices muralidharJustice rajiv shakdherJustice singhRuchir bhatiaJustice prathiba singhStates dtaasMitsubishi corporationEnterprises aesHigh courtDivision benchDelhi high courtIncome tax actMetal oneAssociated enterprisesIndia united states

The Commissioner Of Income Tax-Ii vs Mitusubishi Corporation India P Ltd on 16 February, 2024

The Commissioner Of Income Tax-Ii vs Mitusubishi Corporation India P Ltd on 16 February, 2024
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United statesAsia pteSandeep yadavStates dtaasPrathibam singhRuchir bhatiaDeeksha guptaSanjiv khannaRajiv shakdherTarun singhJustice muralidharJustices muralidharHusnal syali nagiMayank nagiJustice singhJustice prathibam singh

HC declines to entertain Issues not raised before statutory authority

Delhi High Court declines to entertain certain issues raised in appeals due to failure to raise them before the statutory authority.

Ruchir bhatiaIndian dtaasIndian dtasEnterprises aesAmadeus it groupDelhi high courtModel tax conventionIncome taxIncome tax appellate tribunalPermanent establishmentIndia spain double taxation avoidance agreementAssociated enterprisesRisks analysisIncome tax rulesAssessment yearIncome tax international

ALP Adjustment Falls Within Tolerance Band Of +/- of 5%: ITAT Deletes TP-Adjustment On Payment For Consultancy, Professional Fees

The Delhi Bench of Income Tax Appellate Tribunal (ITAT) has deleted the TP adjustment on payment for consultancy and professional fees and other services by the assessee to its Associated Enterprises.

Enterprises aesDelhi benchIncome tax appellate tribunalAssociated enterprisesAnubhav sharmaJudicial memberAccountant memberIncome tax actTransfer pricingLength pricingTransfer pricing officerLength priceFor appellantLp adjustmentLp adjustmentProfessional fees