Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
EXPORT INCENTIVES AND SUBSIDIES – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
DONATION – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
WHETHER EXPENSES DISALLOWED BY AO CAN BE CLAIMED AS NON-OPERATING IN NATURE FOR OPERATING MARGIN COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. During the assessment, the AO may disallow expenditure incurred by the taxpayer on various grounds like they are personal in nature, they are bogus expenditure, etc. The disallowance of the AO would […]
CIT v GE INDIA TECHNOLOGY CENTRE PVT LTD (Kar HC) ITA No. 2013 – ALP OF INTEREST PAID ON ECB
The assessee, GE India Technology Centre Pvt Ltd, is engaged in the business of R&D in the area of material sciences and process technology and providing related software development services. During AY 206-07, the Assessee had obtained 2 External commercial borrowings (ECBs) from its AEs. The rate of interest on ECBs were fixed @ 7.5% […]
PROVISIONS WRITTEN BACK – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
AMORTISATION OF VALUE OF INVESTMENTS – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
SPECIAL WARRANTY PROVISION – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
LOCAL AREA TAXES – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
INCOME TAX REFUND – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]