Home Highlights November 2018 Year 2018 This

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1. TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not...

2. TP Adjustment - MAM Adjustment - ALP adjustment -In TNMM what is to be seen is the functional comparability and not the product comparability. Further, it is observed...

3. TP adjustment - Intragroup services filed by the assessee from its AE - Either way when the Revenue seeks to disturb the Most Appropriate Method adopted by the assessee,...

4. Transfer pricing - determination of ALP - selection of MAM - application of CUP method as against TNMM - AO/TPO directed first apply CUP using some comparable instances...

5. TP Adjustment - selection of MAM - RPM or TNMM or Profit Split method [PSM] - Assessee has came out with a contention that if the TNMM is to be applied, then its...

6. Penalty u/s 271G - assessee applied TNMM for determining of ALP - information/documents sought for determining of ALP as per CUP method - the difficulty in maintaining...

7. TP adjustment - ALP determination - Selection or change in Most Appropriate Method (MAM) - “Other Method" v/s "CUP Method" - Assessee can resile from the most...

8. TP Adjustment - TPO arriving ALP by using TNMM Method and rejecting the CPM Method used by the appellant company for the purpose of determining ALP - In any case, the...

9. TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

10. Most appropriate method for determining the ALP of the royalty - Transfer of intangibles - matter remitted back to the AO/TPO for determination of ALP of royalty by...

11. TP adjustment - We are unable to concur with the aforesaid manner in which the TPO had determined the ALP of the referral services rendered by the AE, viz. CLSA, Hong...

12. 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...

13. Transfer pricing adjustment - in the absence of a machinery provision it would be hazardous for any TPO to proceed to determine the ALP of such a transaction since BLT...

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

15. 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...