Home Highlights November 2018 Year 2018 This

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1. 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...

2. Transfer pricing adjustment - determination of ALP - Once the CIT (Appeals) has rejected the entity level profit margin of the assessee for the purpose of bench marking...

3. 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...

4. TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

5. TPA - This is a case in which transfer pricing provisions cannot be applied because the application of ALP adjustment will indeed result in erosion of Indian tax base-...

6. 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...

7. Transfer pricing adjustment - determination of ALP - Not only changing the tested party from the assessee to its AE, the CIT (Appeals) has also selected a domestic...

8. TPA - ALP - Provision of expenses - The AO has misunderstood the provision debited and credited to the price support account as a mere provision and not as an actual...

9. TPA - determination of ALP - TP adjustment by applying Bright Line Test (BLT) is not sustainable on protective basis having no statutory mandate.

10. Applicability of Transfer pricing provisions - Transactions with joint venture - transactions between the assessee and IJMII do not fall under section 92B(2) -...

11. TPA - Application of the proviso to Section 92C(2) - ALP determination - option available to an assessee in the fixation of the arms length price [ALP for brevity] under...

12. Transfer pricing - the transaction in the instant case of sale of shares in ‘AB’ International will have to be benchmarked as per the transfer pricing provisions...

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

14. 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...

15. Transfer pricing adjustments - determination of ALP - Functional profile not considered – transactions are akin to trading and cannot be considered activities of a...