Transfer pricing adjustment – Since the profit margin of the ...

Entity's Profit Margin Aligned with Comparable Entities; No Transfer Pricing Adjustment Needed Thanks to Safe Limit Compliance.

February 12, 2014

Case Laws Income Tax AT

Transfer pricing adjustment – Since the profit margin of the assessee after taking into consideration the DEPB benefit as part of its turnover comes to 12.30% as against the average net profit margin of 13.05% of the comparables which is within the safe limit of 5% - no TP adjustment - AT

View Source

← Previous Next →

Transfer pricing adjustment – Since the profit margin of the ...

Entity's Profit Margin Aligned with Comparable Entities; No Transfer Pricing Adjustment Needed Thanks to Safe Limit Compliance.

February 12, 2014

Case Laws Income Tax AT

You may also like:

Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

TP adjustment in Distribution activity, described as ESAS - ALP and the consequential transfer pricing adjustment are contemplated only in respect of the international...

ITAT adjudicated transfer pricing dispute regarding comparable company selection. The tribunal determined the Arm's Length Price (ALP) computation by the Transfer...

ITAT excluded four entities (Eclerx Services Ltd., TCS E-serve Ltd., Infosys BPO Ltd., and Tech. Mahindra Ltd.) from the comparable array in transfer pricing adjustment....

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...

TP Adjustment - determination of Arm’s Length Price (ALP) - The products are unique and not comparable to others. The terms and conditions and the economic circumstances...

The Assessee paid royalty to non-UK entities without entering into an Advance Pricing Agreement (APA) or Mutual Agreement Procedure (MAP) proceedings for the assessment...

Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

Transfer pricing - selection of comparable - Capacity adjustment to account for differences in capacity utilization of the Appellant vis-à-vis the comparable -...

Transfer pricing - arm's length price - Selection of comparable - Other enterprises have claimed depreciation at much lower amounts. Size of the assets besides the age...

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

Transfer pricing adjustment - adjustment in respect of international transaction relating to export of manufactured IC engines by considering the difference in the gross...

ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal upheld the TPO's rejection of the assessee's transfer pricing study,...

Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections...

Deduction u/s 80IA in respect of profits of captive power plants ('CPPs') - The tribunal, referring to the Comparable Uncontrolled Price (CUP) method and previous...

Quick Updates: