Welcome to TaxTMI ✕

We're migrating from taxmanagementindia.com to taxtmi.com and wish to make this transition convenient for you. We welcome your feedback and suggestions. Please report any errors you encounter so we can address them promptly.

TMI Blog

Home /

Previous Next

Transfer Pricing Adjustments Challenged: Transactions Misclassified as Trading Instead of Commission Activities, Ignoring Functional Profile Analysis.

X X X X Extracts X X X X

Full Text of the Document

X X X X Extracts X X X X

....Transfer pricing adjustments - determination of ALP - Functional profile not considered – transactions are akin to trading and cannot be considered activities of a commission agent or a broker - HC....

Previous Next

Income Tax

Allied (Direct Tax)

International Taxation

Income Tax Case Laws

Transfer Pricing Adjustments Challenged: Transactions Misclassified as Trading Instead of Commission Activities, Ignoring Functional Profile Analysis.