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 January 2023 Year 2023 This

TP adjustment - Design Engineering Services - Selection of ...

Income Tax

January 25, 2023

TP adjustment - Design Engineering Services - Selection of comparable - Since the assessee is not providing any Software services and the software services of this company constitute around 78% of its revenue and further that no segmental information is available, we hold that this company cannot be treated as comparable. We, therefore, order to exclude it from the list of comparables. - AT

View Source

 


 

You may also like:

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

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

  3. TP Adjustment - Design Engineering Services - in the TP study report assessee applied margins at the entity level - it cannot be precluded from furnishing segmental...

  4. TP Adjustment - Engineering services and Administrative Support services - TPO has rejected the segmental approach adopted by the assessee for benchmarking its...

  5. 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...

  6. 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...

  7. 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...

  8. 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...

  9. TP Adjustment - amount disallowed by the AO, viz., Product development expenses, provision for customer claims should be excluded from the cost while computing margin of...

  10. TP Adjustment - risk based assessment and selection of comparable - The glaring fallacy in the approach of the TPO lies on the fact that he has adopted FOB cost of goods...

  11. TP Adjustment - apportioning the expenses of assessee’s affiliates - Also noted that the assessee has received certain services from its AE which has been treated by the...

  12. Transfer pricing adjustments - Location Savings and Imputation of mark-up on pass through costs - this intra-group services rendered by the assessee to the parent...

  13. TP Adjustment - Benchmarking of interest receivable on loan - when the assessee has charged higher interest on loan to subsidiary compared to the prevailing interest...

  14. Levy of Service Tax - Design Services or not - The definition of “design services” is very clear and it is wide enough to cover all “design services.” Merely because...

  15. Consulting Engineering Service - appellant is a unit of SAIL, engaged in in-house design and engineering activities for all the units of SAIL - service provided to...

 

Quick Updates:Latest Updates