Home Highlights March 2014 Year 2014 This

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1. Transfer pricing - determination of ALP - selection of MAM - application of CUP method as against TNMM - AO/TPO directed first apply CUP using some comparable instances...

2. TP adjustment - ALP determination - Selection or change in Most Appropriate Method (MAM) - “Other Method" v/s "CUP Method" - Assessee can resile from the most...

3. TP Adjustment - ALP of International Transactions of import of fixed assets - Even though the Ld. TPO had mentioned that he is following CUP method as the most...

4. TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

5. When direct CUP between the AE and Tata Communications from whom the assessee has taken the network on lease is available then the ALP has to be computed under CUP -...

6. Penalty u/s 271G - assessee applied TNMM for determining of ALP - information/documents sought for determining of ALP as per CUP method - the difficulty in maintaining...

7. Transfer pricing adjustment - CUP method as the Most Appropriate Method for determination of ALP for international transactions. The assessee is also directed to...

8. TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net...

9. TPA - ALP determination - AO/TPO directed to adopt CUP method for the medical transcription services and TNMM for the software development services - AT

10. Method of valuation - Applicability of most appropriate rule for valuation - it is not the method of valuation that determines the applicability but that the method...

11. Transfer pricing (TP) adjustments - The method adopted by the TPO suffered from the defect of the comparing uncomparable chemicals, using an average variation between...

12. Amends notification No. 124/2007-Customs, dated 31st December,2007 so as to continue, up to and inclusive of 27th March, 2013, the anti-dumping duty on imports of Flat...

13. Refund of service tax - input services - port services - The rejection of refund claim is with respect to Service Tax paid on Port Services and not Customs House Agent...

14. Most appropriate method for determining the ALP of the royalty - Transfer of intangibles - matter remitted back to the AO/TPO for determination of ALP of royalty by...

15. Disallowance of payments made for royalty and technical know-how received - Accepted Most appropriate method for benchmarking the manufacturing segment as TNNM -...