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In the case of Tecnimont ICB House vs. DCIT, ITAT has held that Recovery of expenses beyond the normal period was in the nature of deemed loan in the hands of AEs and require transfer pricing adjustment.
The assessee-company was engaged in the business of manufacture of pre-engineered building system products. During relevant year, assessee entered into international transactions with its AE situated in Kuwait.
Royalty means payment of any kind received as consideration for the use of or right to use any intangible property like patent, copyright, design or model, secret formula or process, trademark, trade name or for information concerning industrial, commercial or scientific experience.
In this case ITAT examined that whether Arm’s Length Price (ALP) adjustments will also be warranted in case of interest free loans extended as quasi capital and what are the connotations of expression ‘quasi capital’ in the context of the transfer pricing legislation.
The transaction of allowing credit period to the AE on realization of sale proceeds is not an independent transaction and has to be considered along with the main international transaction of sale of goods.
Assessee had reduced its operating expenses to calculate ratio of operating profit/Total cost which was the base to calculate the value of export of goods in transfer pricing on the basis that it was its first year of operation
Assessee was engaged in the field of providing insurance & Human Resources services to its associated enterprise in UK. The Ld. AO /TPO made an addition to the income of the assessee by comparing the income of the assessee with the income of the comparable companies
In the present facts of the case the Hon’ble High Court held that as the assessee have not taken substantial risks and was a mediator in the international transactions. Hence, Transactional Net Margin Method is a right method instead of Profit Split method.
Transfer Pricing is the setting of the price for goods and services sold between controlled/related legal entities. It is generally aimed at depicting favourable performance of a conglomerate by shifting earnings from a high tax jurisdiction to a low-tax one.
Whether the transactions between the head office in India and branch office in Canada can be considered as international transactions? The assessee had entered into certain transaction with his branch office in Canada. The AO had taken these transactions also into sweep for the purposes of making the transfer pricing adjustment.
