{"id":14342,"date":"2020-12-08T11:38:02","date_gmt":"2020-12-08T11:38:02","guid":{"rendered":"https:\/\/itatonline.org\/digest\/vishwas\/transfer-pricing-adjustment\/"},"modified":"2020-12-08T22:31:44","modified_gmt":"2020-12-08T22:31:44","slug":"transfer-pricing-adjustment","status":"publish","type":"vishwas","link":"https:\/\/itatonline.org\/digest\/vishwas\/transfer-pricing-adjustment\/","title":{"rendered":"Transfer Pricing adjustment"},"content":{"rendered":"<p>In case of my client, Transfer Pricing adjustment has been made because of which my returned loss is converted into a taxable income. However, the client is having brought forward business losses which if adjusted will lead to a NIL income. The AO has also initiated penalty under section 271(1)(c), 271AA and 271G.<br \/>\nThe AO has passed the assessment order without offsetting the previous year losses. Rectification application is filed however the order is awaited. The following are our queries.<br \/>\n1. Can we offset the losses at the time of filing VSV.<br \/>\n2. If we opt for VSV whether penalty under section 271(1)(c), 271AA and 271G would be waived off?<\/p>\n","protected":false},"excerpt":{"rendered":"<p>In case of my client, Transfer Pricing adjustment has been made because of which my returned loss is converted into a taxable income. However, the client is having brought forward business losses which if adjusted will lead to a NIL income. The AO has also initiated penalty under section 271(1)(c), 271AA and 271G. The AO has passed the assessment order without offsetting the previous year losses. Rectification application is filed however the order is awaited. The following are our queries. 1. Can we offset the losses at the time of filing VSV. 2. If we opt for VSV whether penalty under section 271(1)(c), 271AA and 271G would be waived off?<\/p>\n<p><a href=\"https:\/\/itatonline.org\/digest\/vishwas\/transfer-pricing-adjustment\/\">read more<\/a><\/p>","protected":false},"comment_status":"open","ping_status":"closed","template":"","tags":[],"expertname":[6],"class_list":["post-14342","vishwas","type-vishwas","status-publish","hentry","expertname-dr-k-shivaram-sr-advocate"],"acf":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/vishwas\/14342","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/vishwas"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/vishwas"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=14342"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=14342"}],"wp:term":[{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=14342"},{"taxonomy":"expertname","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/expertname?post=14342"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}