TP Adjustments - Disregarding Profit Split Method ('PSM') as the ...

Income Tax

May 30, 2015

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 MAM and by allocating residual profits based on the relative value of each enterprise's contribution - AT

View Source

← Previous Next →

TP Adjustments - Disregarding Profit Split Method ('PSM') as the ...

Income Tax

May 30, 2015

You may also like:

TP adjustment - MAM selection - method used for benchmarking the royalty transaction - It may be true that the assessee aggregated payment of royalty with the...

TP - The transfer pricing report furnished by the assessee is not in accordance with rules prescribed in this regard - The PSM has not been correctly applied as per law...

TP Adjustment - the TPO is erred in adopting CUP method for few transactions when he has accepted overwhelming majority of transactions under TNMM method. The DRP...

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...

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

TP Adjustment - International transactions with its AEs for providing software consultancy services - Selection of MAM - DRP without appreciating the above facts, has...

Transfer pricing adjustment - the conclusion of the TPO that the PSM is adopted by the assessee only to camouflage loss at the net level is merely an allegation and...

TP adjustment - application of the Resale Price Method (RPM) as the Most Appropriate Method (‘MAM’) - trading activity - The decision of Supreme Court in Kedarnath Jute...

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...

TP Adjustment - MAM selection - TNMM or RPM - It is not the case that assessee has resold the same goods with only minor modifications to justify the adoption of RPM as...

Quick Updates: