Home Highlights October 2014 Year 2014 This

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1. TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

2. TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

3. Transfer pricing adjustment - determination of ALP - Once the CIT (Appeals) has rejected the entity level profit margin of the assessee for the purpose of bench marking...

4. TPA - This is a case in which transfer pricing provisions cannot be applied because the application of ALP adjustment will indeed result in erosion of Indian tax base-...

5. TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not...

6. TP Adjustment - Interest on extended credit to AE - assessee granted extended credit periods to non-AEs without charging any interest on delayed payments - CIT(A) has...

7. TPA - ALP determination - Without complying to the statutory provisions, the Transfer Pricing Officer certainly cannot determine the arm's length price on ad-hoc /...

8. Transfer pricing adjustment - determination of ALP - Not only changing the tested party from the assessee to its AE, the CIT (Appeals) has also selected a domestic...

9. TP Adjustment - determination of arm’s length price, ALP - Transactions with the local vendors the terms of which are not influenced by Comer SpA cannot be treated as...

10. Transfer pricing adjustments - determination of ALP - Functional profile not considered – transactions are akin to trading and cannot be considered activities of a...

11. Transfer pricing adjustment – Determination of ALP of International License Revenue - Cost of international rights – media rights in respect of BCCI cricket - decided...

12. Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

13. TP adjustment in Distribution activity, described as ESAS - ALP and the consequential transfer pricing adjustment are contemplated only in respect of the international...

14. Transfer Pricing Adjustment - Transfer Pricing Regulations do not contemplate taking into account future data for the purpose of bench marking - AT

15. Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...