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1. 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...

2. 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...

3. U/s 92C(2) of IT Act 1961- Computation of arm's length price - price variance upto 1% in case of wholesale trade and 3% in all other cases will be allowed.

4. Transfer pricing - Computation of Arm's length price - Notified percentage under second proviso to section 92C(2) - Notification

5. 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)...

6. Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

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

8. Valuation of imported goods - inter-se relation having any influence on the transaction value of imports, or not - If the price declared was at arm’s length, then...

9. Computation of arm's length price - tolerance limit of 1% in case of wholesale trading and 3% in other cases notified - U/s 92C(2) of IT Act 1961 - Notification

10. U/s 92C(2) of IT Act 1961- Computation of arm's length price - specifies the tolerance limit in case of wholesale trading and other cases - Notification

11. Royalty Benchmarking - assessee had adopted TNMM at the entity level in which process royalty payment is considered as closely linked transaction and part of operating...

12. Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

13. 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...

14. Valuation - clearance of pipes - inter-connected undertakings - arms length price - Rule 10 (a) would apply only if such clause is specified in the Show Cause Notice...

15. Penalty u/s 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it...