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 February 2015 Year 2015 This

Transfer pricing adjustment - AO/TPO/DRP not appreciating the ...


Court Reviews Transfer Pricing Methodology in Freight Forwarding Dispute: TNMM vs. CUP Method for Arm's Length Assessment.

February 4, 2015

Case Laws     Income Tax     AT

Transfer pricing adjustment - AO/TPO/DRP not appreciating the 50:50 revenue split business model between the appellant and its associated enterprises in relation to international transactions, i.e. provision and receipt of freight forwarding services, and, further making an upward adjustment alleging that such transactions were not at arm’s length - TNMM v/s CUP method? - AT

View Source

 


 

You may also like:

  1. ITAT adjudicated transfer pricing dispute involving manufacturing and service segments. Tribunal found substantial merit in assessee's contentions regarding arm's length...

  2. The High Court considered the maintainability of a review petition based on a subsequent judgment and the condonation of a 619-day delay in filing the civil review...

  3. The High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) which had approved the Comparable Uncontrolled Price (CUP) method adopted by the assessee for...

  4. The High Court held that a change in the approach of assessing tax, without any statutory change, leads to uncertainty in cash flow and fund flow, which are crucial for...

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

  6. The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

  7. ITAT adjudicated transfer pricing dispute involving international transactions between an assessee and its Associate Enterprise. The tribunal upheld the transfer pricing...

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

  9. The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

  10. In the matter under review, the High Court dismissed the review petitions filed by the parties. The Court held that no grounds were established for seeking a review of...

  11. This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

  12. ITAT adjudicated transfer pricing dispute regarding software development services benchmarking. The Tribunal comprehensively examined functional comparability, rejecting...

  13. ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely...

  14. Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

  15. This case deals with the levy of deficit stamp duty and penalty in a court-conducted auction sale. The key points are: In a court-supervised auction sale, the stamp...

 

Quick Updates:Latest Updates