![LIBOR is appropriate Benchmarking Rate for determining ALP on outbound Loan Transactions: ITAT dismisses Appeal [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/07/LIBOR-appropriate-Benchmarking-Rate-ALP-outbound-Loan-Transactions-ITAT-Appeal-taxscan.jpg "LIBOR is appropriate Benchmarking Rate for determining ALP on outbound Loan Transactions: ITAT dismisses Appeal [Read Order]")
LIBOR is appropriate Benchmarking Rate for determining ALP on outbound Loan Transactions: ITAT dismisses Appeal [Read Order]
The Income Tax Appellate Tribunal (ITAT) Delhi Bench ruled that LIBOR is appropriate benchmarking rate for determining Arm's Length Price (ALP) on...
![ITAT upholds Revision Order due to Non-Compliance with ALP Determination Requirement [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/05/ITAT-upholds-Revision-Order-ALP-Determination-Requirement-Revision-Order-ITAT-Income-Tax-taxscan.jpg "ITAT upholds Revision Order due to Non-Compliance with ALP Determination Requirement [Read Order]")
![ESOP Expenses Eligible for Deduction u/s 37 of Income Tax Act: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/05/ESOP-Expenses-Expenses-ESOP-Deduction-ESOP-Expenses-Eligible-for-Deduction-Income-Tax-Act-Income-Tax-taxscan.jpg "ESOP Expenses Eligible for Deduction u/s 37 of Income Tax Act: ITAT [Read Order]")
![Relief to Ambuja Cement: ITAT deletes ALP adjustment of 18 lakhs [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/12/Relief-to-Ambuja-Cement-ITAT-deletes-ALP-adjustment-TAXSCAN.jpg "Relief to Ambuja Cement: ITAT deletes ALP adjustment of 18 lakhs [Read Order]")
![Determination of ALP for Royalty Payment: Delhi HC dismisses Income Tax Department’s Appeal against Amway India [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/10/ALP-Royalty-Payment-Delhi-HC-Income-Tax-Departments-TAXSCAN.jpg "Determination of ALP for Royalty Payment: Delhi HC dismisses Income Tax Department’s Appeal against Amway India [Read Order]")
Relief to Ferrero India: ITAT holds on absence of international transaction determination of ALP not necessary [Read Order]
Relief to Ferrero India Pvt Limited was granted by the Income Tax Appellate Tribunal (ITAT), Pune as on absence of international transaction determination of ALP (Arm Length Price) not necessary. ...
![Relief to Ferrero India: ITAT holds on absence of international transaction determination of ALP not necessary [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/09/Ferrero-India-ITAT-ALP-taxscan.jpeg "Relief to Ferrero India: ITAT holds on absence of international transaction determination of ALP not necessary [Read Order]")
Corporate Guarantee Falls within the Scope and Ambit of International Transaction, ALP Applicable at 0.5%: ITAT [Read Order]
The Bangalore Bench of Income Tax Appellate Tribunal has held that corporate guarantee falls within the scope and ambit of international transaction and Arm’s Length Price (ALP) applicable at 0.5%. ...
![Corporate Guarantee Falls within the Scope and Ambit of International Transaction, ALP Applicable at 0.5%: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2022/04/Corporate-Guarantee-Scope-Ambit-International-Transaction-ALP-Applicable-ITAT-taxscan.jpeg "Corporate Guarantee Falls within the Scope and Ambit of International Transaction, ALP Applicable at 0.5%: ITAT [Read Order]")
In absence of any Income issue of applying measure of ALP to Transactional Value itself would not arise: Gujarat High Court [Read Order]
The Gujarat High Court ruled that in absence of any income issue of applying a measure of Arm’s Length Price (ALP) to transactional value itself would not arise. The writ applicant, Hitachi...
![In absence of any Income issue of applying measure of ALP to Transactional Value itself would not arise: Gujarat High Court [Read Order]](https://www.taxscan.in/wp-content/uploads/2021/08/ALP-transactional-value-Gujarat-High-Court-Taxscan.jpg "In absence of any Income issue of applying measure of ALP to Transactional Value itself would not arise: Gujarat High Court [Read Order]")
ALP and Resultant Excess Profit to be treated as Deemed Income under 'Other Sources': Madras High Court [Read Order]
The Madras High Court ruled that the Arm's Length Price (ALP) and resultant excess profit to be treated as deemed income under 'other sources'. The assessee/respondent, M/s.Tweezerman (India)...
![ALP and Resultant Excess Profit to be treated as Deemed Income under Other Sources: Madras High Court [Read Order]](https://www.taxscan.in/wp-content/uploads/2021/07/ALP-deemed-income-other-sources-Madras-High-Court-Taxscan.jpg "ALP and Resultant Excess Profit to be treated as Deemed Income under Other Sources: Madras High Court [Read Order]")
TPA made at entity level should be restricted to international transactions only: ITAT grants Partial Relief to Tasty Bite Eatables [Read Order]
The Income Tax Appellate Tribunal (ITAT), Pune Bench ruled that the Transfer Pricing Adjustment (TPA) made at entity level should be restricted to international transactions only. The assessee,...
![TPA made at entity level should be restricted to international transactions only: ITAT grants Partial Relief to Tasty Bite Eatables [Read Order]](https://www.taxscan.in/wp-content/uploads/2021/06/TPA-ITAT-Tasty-Bite-Eatables-Taxscan.jpg "TPA made at entity level should be restricted to international transactions only: ITAT grants Partial Relief to Tasty Bite Eatables [Read Order]")
Invoice on AE to be raised to Recover Excess Payment, If Royalty exceeds its ALP as per Advance Pricing Agreement: ITAT
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench ruled that if payment of royalty by the GIA India to the assessee was to exceed its arm’s length price, as determined in the APA, the applicant,...
ITAT upholds ALP of corporate guarantee as determined 0.43% p.a, directs the AO to vacate the upward transfer pricing adjustment [Read Order]
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench upheld the Arm’s Length Price (ALP) of corporate guarantee as determined 0.43% per annum and directed the AO to vacate the upward transfer...
![ITAT upholds ALP of corporate guarantee as determined 0.43% p.a, directs the AO to vacate the upward transfer pricing adjustment [Read Order]](https://www.taxscan.in/wp-content/uploads/2021/04/ITAT-ALP-corporate-guarantee-AO-upward-transfer-pricing-adjustment-Taxscan.jpg "ITAT upholds ALP of corporate guarantee as determined 0.43% p.a, directs the AO to vacate the upward transfer pricing adjustment [Read Order]")