Home Highlights April 2014 Year 2014 This

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1. TP Adjustment - selection of MAM - RPM or TNMM or Profit Split method [PSM] - Assessee has came out with a contention that if the TNMM is to be applied, then its...

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. 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...

4. TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not...

5. 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...

6. Loss incidental to business - non-recovery of certain business advances - Once assessee had any business transaction with any party during the course of which if...

7. TP Adjustment - ALP determination qua domestic transactions entered into by the assessee with its partner u/s 92BA(i) of the Act - no addition on account of TP...

8. Forex loss - allowable business loss u/s 37(1) or not? - The assessee company has entered into transactions of buying and selling of forex and incurred a loss on the...

9. TPA - determination of ALP - TP adjustment by applying Bright Line Test (BLT) is not sustainable on protective basis having no statutory mandate.

10. TP Adjustments - Disregarding Profit Split Method ('PSM') as the most appropriate method for benchmarking - TPO, should determine the ALP by adopting residual PSM as the...

11. 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 -...

12. TPA - selection of MAM for determining ALP of transaction - APM v/s RPM - Ld.AO/TPO erred in not conducting fresh search of comparables which would have strict...

13. TP Adjustment - MAM Adjustment - ALP adjustment -In TNMM what is to be seen is the functional comparability and not the product comparability. Further, it is observed...

14. TP Adjustment - benefit test - authorities below have fatally erred in applying the benefit test as rightly contended by the Ld. Counsel of the assessee. Furthermore, it...

15. TPA - Application of the proviso to Section 92C(2) - ALP determination - option available to an assessee in the fixation of the arms length price [ALP for brevity] under...