Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights September 2022 Year 2022 This

TP Adjustment - tested party - No infirmity in the order of the ...

Income Tax

September 7, 2022

TP Adjustment - tested party - No infirmity in the order of the learned CIT(A) in directing the assessee to adopt the foreign associated enterprise as tested party with respect to 1st set of transactions, not to aggregate the first set of transaction and second set of transactions for benchmarking, exclusion of e–clerk services limited and TCS e–serve international Limited for benchmarking second set of transactions. - AT

View Source

 


 

You may also like:

  1. TP Adjustment - Rejection of Associated Enterprises as the tested party - foreign Associated Enterprises satisfied all the criteria for being taken as a tested party....

  2. TP Adjustment - tested party for the purpose of determination of Arm's Length Price - Revenue seeks to pin the assessee based upon the auditor's certification as filed...

  3. TP Adjustment - secondment of employees by Assessee to its AE - the benchmarking done by the TPO by applying the same rate of thirty party placement agency is not...

  4. TP Adjustment - No adjustment towards working capital has been allowed to the assessee - One has to see that reasonable adjustment is being made so as to bring both...

  5. TP Adjustment - the TPO is erred in adopting CUP method for few transactions when he has accepted overwhelming majority of transactions under TNMM method. The DRP...

  6. TP adjustment - onsite development and project coordination fee’ - Associated enterprise can be considered as a tested party, in the present case. Accordingly, we direct...

  7. TP adjustment - tested party - As per Guidance Note on report u/s 92E and transfer pricing guidelines issued by the OECD and united nation practical manual of transfer...

  8. TP Adjustment - US Transactions non US Transactions - scope of MAP agreement - It would be better to refer to the settlement arrived between the competent authority of...

  9. TP Adjustment - CIT(A) under the garb of "rule of consistency" adopted the TP analysis made by the TPO - This method of TP analysis is unheard of as every assessment...

  10. TP Adjustment - AMP expenses by applying bright line test on protective basis - TP adjustment amounting by applying BLT is not sustainable on protective basis having no...

  11. TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result...

  12. TP adjustment - benchmarking of international transaction of import of raw materials - the TP adjustments in respect of this transaction should be restricted in terms of...

  13. TP Adjustment - Reduction of economic adjustment on foreign exchange fluctuation loss - in principle, the foreign exchange fluctuation loss adjustment has to be given...

  14. TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...

  15. TP Adjustment - Working capital adjustment - Making a working capital adjustment is an attempt to adjust for the differences in time value of money between the tested...

 

Quick Updates:Latest Updates