Thursday, May 16, 2013

Section 92C: Transfer Pricing

The Delhi ITAT bench has held that in case of transaction of lending money in foreign currency to foreign subsidiary, LIBOR should be taken as benchmark rate for computing ALP of interest.

The Mumbai ITAT bench has held that foreign exchange gain, if related to business of assessee profit, will be a part and parcel of arm's length price profit.

The Hyderabad ITAT bench has held that while computing ALP, companies having super normal profits and companies with extraordinary circumstances like merger/de-merger etc. cannot be taken as comparables

The Delhi ITAT bench has held that the “Bright Line test” can be applied to disallow the excessive AMP expenses incurred by the assessee for the benefit of the brand owner.

The Chennai ITAT bench has explained law on valuation of shares of a closely held company for transfer pricing purposes.


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