Simone Coccia Coliuta messo subito a Chi è la fidanzata di Simone Coccia Colaiuta? Grafica Veneta Azienda cerca 25 operai ma si presentano solo in 4Grafica Veneta: non troviamo operai. Sunil Moti Lala, Advocate, has prepared a compilation of important judgements structural design and drawing by krishna raju pdf transfer pricing, international tax and domestic tax reported in the period from January to June 2016. The author has meticulously and systematically classified the judgements into various categories to enable ease of reference.
A pdf copy of the digest is available for download. The Digest comprises of 700 judgements of which 320 deal with transfer pricing and international taxes cases. There are 380 cases on various issues of domestic taxation laws. A brief head note is given for each case. The Tribunal held that the impugned transaction i. AE, which was immediately paid to a third party as an advance for purchase of film rights did not fall within the purview of international transaction under section 92B since the transaction was not between two associated enterprises, but in fact between the assessee and a third party and that too for the acquisition of rights and not as a loan or source of finance.
D Cess and tax paid on technical know-how royalty could not be treated as an international transaction and since royalty payment was at arm’s length price, no disallowance could made by the TPO. The Tribunal held that in the absence of an agreement between the Indian entity and foreign AE whereby the Indian entity was obliged to incur AMP expenditure of a certain level for the foreign AE for the purpose of promoting the brand value of its products, no international transaction could be presumed and that mere presence of incidental benefit to the foreign AE would not imply that the AMP expenses incurred by the Indian entity were for promoting the brand of the foreign AE. Further, it held that even if TNMM was found acceptable as regards all other transactions, it was open to the TPO to segregate a portion and subject it to an entirely different method i. CUP if the assessee did not provide satisfactory replies to his queries. The Tribunal held that in the absence of an agreement between the assessee and its AEs for the sharing of AMP expenses, the TPO was incorrect in concluding that the AMP expenses incurred by the assessee were for the benefit of its AEs and accordingly the AMP expenses could not be treated as an international transaction. The Tribunal held that in the absence of any direct evidence of incurrence of AMP expenses by the assessee for the benefit of its AE or on behalf of its AE, the AMP expenses could not be treated as an international transaction under section 92B of the Act.
It held that probable incidental benefit to the AE would not make the transaction an international transaction. The Tribunal, held that the royalty paid by the assessee to Jockey International Inc was not an international transaction and therefore could not be subjected the provisions of Chapter X since Jockey was not an AE of the assessee as per Section 92A of the Act. The Tribunal, relying on the decisions of the Tribunal in the cases of Sumitomo Corporation India Pvt Ltd and Marubeni India P Ltd held that the internal CUP method was the most appropriate method to benchmark the assessee’s commission for provision of indenting services as opposed to the Profit Split Method sought to be applied by the TPO and that where there was no data to support the CUP method, the TNMM method was to be applied. The Tribunal held that where the arms’ length price of the transactions undertaken by the assesse viz. AE was justified and accepted by the TPO under the CUP method on the basis of the meanof prices of pulses obtained from a website called agriwatch. The Tribunal deleted the TP adjustment in respect of export of chemicals to AEs on the basis of the CUP method, observing that the assessee was bound to sell the chemicals to its AE at lower prices to recover its manufacturing costs since it was obsolete stock and there was no room for determination of prices based on free interplay of demand and supply. N L C Nalco India Ltd.
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