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ITAT Mumbai held that adjustment of notional interest for extended credit period to the associated enterprises unsustainable as assessee extended credit period to its non-associated enterprises without charging any interest.
Explore the details of the case between Voith Siemens Hydro Private Limited and ACIT regarding transfer pricing proceedings. Analyze the expenses incurred for engineering services and administrative support services, the examination of invoices, and the arguments presented. Understand the outcome and implications of the case.
ITAT Mumbai held that the bank guarantee rates cannot be considered for benchmarking corporate guarantee fees, therefore benchmarking of AO and DRP is also incorrect. It depends on creditworthiness of parties and benefit arising out of the same in the hands of the parties to the transaction.
Held that internal CUP [internal Comparable Uncontrolled Price Method] is the most appropriate method for undertaking the determination of Arm’s Length Price.
ITAT Mumbai held that the moment the order of the TPO is barred by limitation and quashed the assessee ceases to be an eligible assessee. Hence the time limit for completion of the assessment reverts back to 21months. Final assessment order passed after that is barred by limitation.
Understand the Bombay High Court’s ruling on PCIT vs Kimberly Clark Lever Private Limited case regarding the reference to TPO and the scrutiny assessment as per the Income Tax Act 1961.
ITAT Mumbai held that TPO was correct in concluding that the rate at which loan is taken by the Appellant cannot be taken as internal CUP to benchmark the loan given by the Appellant to its AE as there is a difference in credit rating of the Appellant and its AE.
ITAT Mumbai held that the TPO is not correct in arriving at the ALP as NIL on the ground that the need and benefit test is not satisfied by the assessee without giving any contrary findings with regard to the various documents including the TP study submitted by the assessee.
ITAT Mumbai’s decision in case of DCIT vs KEC International Limited, where a 0.6% arm’s length rate was established for corporate guarantee fees, influencing future transfer pricing adjustments.
ITAT Bangalore held that if two out of the three preceding assessment year the comparable has earned profits it cannot be held a persistent loss making company. Hence, persistent loss filter can be applied only if there is loss in three successive assessment years.
