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1. TP Adjustment - comparable selection - The ITAT that the turnover filter cannot be applied as a tool for cherry picking the comparables at the later stage after...

2. TP Adjustment - comparable selection - upper turnover filter - The assessee submits that the turnover of the assessee is only Rs. 124 Crores during the relevant previous...

3. Selection of comparable - TPA - a company cannot be selected as a comparable not only on the reason of failing employee cost filter, but also due to amalgamation during...

4. TPA - One of the comparables Caliber Point Business Solutions has related party transactions of 30% of Revenue and going by the threshold filter of 25% of the related...

5. TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated...

6. TP Adjustment - comparable selection - None of the comparables have been excluded on the ground of high turnover alone. The test of functional similarity applied by the...

7. TPA - comparable selection - companies with revenues less than 75% from software development services would be ideal to be excluded, as economic circumstances of such...

8. TP Adjustment - Comparable selection - TPO on his part has also adopted a filter whereby he has chosen companies having service income of 75% or more in each of the...

9. TP Adjustment - Selection of comparable - An inclusion of certain entity in the list of comparables by the assessee in transfer pricing study report cannot act as...

10. TP adjustment - comparable selection - functinal dissimilarity - media content and TV broadcasting are totally dissimilar activities - not at all comparable - AO/ TPO to...

11. TPA - valid comparable - the accounting period of the comparable company should be the same with that of the assessee-company.

12. Transfer Pricing Adjustments - Selection of the most appropriate method (MAM) for determining the arm's length price (ALP) - The assessee's choice to adopt the 'other...

13. Inclusion of CST turnover into the VAT turnover - TNVAT Act, 2006 - the overlap between the CST Act, 1956 and the TNVAT Act, 2006 and the Rules made thereunder are only...

14. Compounding of offence u/s 276-B - application with wrong officer - compounding fees as first application @ 3% OR as second (subsequent) application @ 5% - whether, the...

15. Transfer pricing adjustment - Turnover is an important filter which has to be adopted for determination of the ALP. The FAR analysis would not alter the turnover of the...