Home Highlights November 2015 Year 2015 This

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1. Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

2. Transfer pricing adjustment - in arriving at the operating cost in transfer pricing matters the principles of Cost Accounting will not be strictly applicable where cost...

3. Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

4. Adjustment towards foreign exchange fluctuation - non-consideration of impact of abnormal movement in the foreign exchange rates while computing the operating profit...

5. Transfer pricing adjustment - computation of the operating profit margin by increasing the cost of the sales leads to an arbitrary adjustment of the Assessee's income...

6. 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) -...

7. TPA - 'operating profit’ from the international transaction is compared with the operating profit margin of the comparables under the TNMM. Thus the addition based on...

8. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

9. 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...

10. Transfer pricing adjustments - TPO directed to take into account 30% additional cost base to account "free of cost" material and revised the OP/TC margin of 13.65% for...

11. Valuation - includability or otherwise of the value of the free-of- cost components - Normally, the cost price of a product would take into account the purchase cost of...

12. Transfer pricing adjustment - adjustment in respect of international transaction relating to export of manufactured IC engines by considering the difference in the gross...

13. Transfer Pricing Adjustments - downward adjustment made by the TPO and enhanced by the CIT(A) - adoption of the Transactional Net Margin Method (TNMM) over other methods...

14. TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...

15. TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result...