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1. TP Adjustment - where the Tribunal has accepted the international transaction to be at Arm’s Length Price in the hands of AE, then the international transaction that the...

2. TP adjustment - Determining the Arm's Length Price of international transactions in respect of "advisory services" - we adopt judicial consistency in the absence of any...

3. Jurisdiction of Transfer Pricing Officer - Suo motu, TPO cannot take cognizance of any international transaction for suggesting adjustment in the arm’ s length price,...

4. TPA - where the variation between the arm’s length price determined u/s 92C and the price at which the international transaction or specified domestic transaction has...

5. Arm Length Price adjustment – The very foundation of addition in arm's length price on account of excess credit period is devoid of any legally sustainable merits or...

6. TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's Length Price is required to be determined for a transaction with specified persons in section 40A(2)(b)...

7. 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...

8. TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from...

9. Imposition of penalty u/s 271G - failure to furnish information or documents in respect of segmental amount relating to transaction made with AEs and non-AEs for...

10. If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

11. Arm's Length Price adjustment on international transaction – selection of comparable - if abnormal loss making companies are excluded abnormal profit making companies...

12. Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The...

13. TP Adjustment - intra group services - The assessee has failed to completely demonstrate the Arm’s Length Price of intra group services by satisfying need test, benefit...

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

15. TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...