Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights March 2018 Year 2018 This

TPA - whether AO should have decided the issue of international ...

Case Laws     Income Tax

March 26, 2018

TPA - whether AO should have decided the issue of international transaction himself instead of referring it to Transfer Pricing Officer as the quantum of International Transaction is below the monetary limit of ₹ 5 crore? - If powers conferred on a particular authority are arrogated by other authority without mandate of law, it will create chaos in the administration of law and hierarchy of administration will mean nothing. Satisfaction of one authority cannot be substituted by the satisfaction of the other authority. - AT

View Source

 


 

You may also like:

  1. Change of jurisdiction u/s 127 - As in the present case, the Assessing Officer rejected the objection regarding the jurisdiction and referred the matter to the PCIT to...

  2. TPA - Jurisdiction of the AO in making the assessment without referring the matter to the Transfer Pricing Officer where the value of international transactions exceeded...

  3. With the passage of time where India is becoming a global commercial hub with the advent of Multinational Companies new transfer pricing issues are thrown up and keeping...

  4. Reopening of assessment u/s 147 - it appears that the AO has recorded to the effect that he could not refer the matter to the Transfer Pricing Officer nor could he...

  5. Amendment of section 92D. - TPA - maintenance and keeping of information and document by persons entering into an international transaction or specified domestic...

  6. TPA - receivables forming a part of international transaction - TPO is not justified in concluding that the figure of receivables beyond 180 days constitutes an...

  7. Transfer pricing - Power of the TPO for suo-moto determination of ALP in respect of international transaction which were not referred to him by the AO - AT

  8. 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...

  9. The ITAT Hyderabad addressed a Transfer Pricing (TP) Adjustment issue regarding interest on outstanding receivables, determining if it constitutes an international...

  10. TP Adjustment - US Transactions non US Transactions - scope of MAP agreement - It would be better to refer to the settlement arrived between the competent authority of...

  11. TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the...

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

  13. TP Adjustment Transaction of slump sale between the subsidiaries of Foreign Holding Company - To be considered as an international transaction or not - The meaning of...

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

  15. TPA - international transaction - any further adjustment only on the basis of the outstanding receivables would have distorted the picture and recharacterised the transaction

 

Quick Updates:Latest Updates