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

2. TP Adjustment - international transactions u/s. 92B or not - In absence on any such agreement, the first and primary condition of holding the transaction in question as...

3. Reopening of assessment u/s 147 - Tribunal was correct to hold that when reference was made to the TPO by AO for determination of arm’s length price in relation to the...

4. TP Adjustment - Interest on delayed receivables - The ITAT found that the conditions laid down by previous rulings, specifically in the case of PCIT vs. Kusum...

5. TP Adjustment - As per the provisions of aforesaid Rule, the ‘other method’ shall be the method which takes into account the price which has been or would have been...

6. TPA - Addition in respect of ALP in respect of receivables due from AEs - Early or late realization of sale proceeds is only incidental to transaction of sale, but not a...

7. TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

8. Determination of transaction - statutory change to section 92CA - AO is now bound by the order of the TPO on the computation of the arm’s length price of an...

9. TP Adjustment - Eligible International Transaction - safe harbor rules - The court examined the eligibility of international transactions under Rule 10TC of the Income...

10. TPA - the jurisdiction and power of TPO is to determine arm's length price of Royalty and the order of TPO holding that the assessee had not derived any benefit under...

11. TPA - computation of ALP of the international transactions by applying BLT - ALP of an international transaction involving AMP expenses, the adjustment made by the...

12. TP Adjustment - notional interest on outstanding receivables due from Associated Enterprises (AES) - assessee not charging any interest from its AEs - Treatment of...

13. 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...

14. TP Adjustment - existence of international transaction of AMP Expenses - the revenue has also substantially proved the onus of existence of international transaction...

15. 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...