TP adjustment - Comparable selection - if finances of the three ...

Case Laws Income Tax

August 3, 2019

TP adjustment - Comparable selection - if finances of the three comparables with reference to their respective annual reports, did show that there was a general trend in the industry of either loss-making or declining revenues and there was no dispute on the functional profile of the Assessee being similar with comparable then loss making companies should not be excluded only on that basis

View Source

← Previous Next →

TP adjustment - Comparable selection - if finances of the three ...

Case Laws Income Tax

August 3, 2019

You may also like:

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

TP adjustment - comparable selection - RTP - the %age of RPT is determined based on the availability of comparables - The more we restrict, chances of loosing reasonable...

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

TP Adjustment - selection of MAM - CUP cannot be applied on basis of comparable uncontrolled transactions- internal or external- that are undertaken in different...

TP Adjustment - selection of comparables - The tribunal directed exclusion of three comparables from the TPO's list, as they were involved in garment manufacturing, not...

TP adjustment - Design Engineering Services - Selection of comparable - Since the assessee is not providing any Software services and the software services of this...

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...

TP Adjustment - comparable selection - before relying upon any judicial precedent for exclusion or inclusion one has to cross the threshold of rule 10 B (2) of IT Rules,...

TP Adjustment - Comparable selection - determination of the arm’s length price (ALP) of international transactions - The appellant contested the inclusion of two...

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...

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...

TP Adjustment - comparable selection - Exclusion of government companies - Because of the absence of the profit motive and discharge of the social obligations, the...

TP Adjustment - comparable selection - where a concern is selected was showing low employee cost to sales ratio, then such concern cannot be selected while benchmarking...

TP Adjustment - Arm's Length Price (ALP) adjustment - The gross margins of assessee are much more than the gross margins of comparable companies chosen by the ld. TPO....

TP Adjustment - main grievance is the non-granting of the adjustment with regard to underutilized capacity - The settled law is that adjustment on account of capacity...

Quick Updates: