Transfer pricing adjustment - ALP - The Ld. DRP has simply ...

Income Tax

June 4, 2015

Transfer pricing adjustment - ALP - The Ld. DRP has simply mentioned that the AO has given cogent and detailed reasons for the same. In our considered opinion, the finding given by the Ld. DRP is not a speaking one and is not sustainable in the eyes of law - AT

View Source

← Previous Next →

Transfer pricing adjustment - ALP - The Ld. DRP has simply ...

Income Tax

June 4, 2015

You may also like:

Transfer pricing adjustment deleted - the comparables adopted by the assessee are uncontrolled parties and can be considered for the purpose of determining the Arms'...

TPA - ALP determination - Without complying to the statutory provisions, the Transfer Pricing Officer certainly cannot determine the arm's length price on ad-hoc /...

Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

Arms' length price adjustment - There is no reasoning and justification for applying the margins earned in trading activity to indenting activity as the two are distinct...

Transfer Pricing adjustments - Arms length price (ALP) - u/s 92CA - software development and IT enabled services - selection of comparable - Size matters in business

TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

TPA - This is a case in which transfer pricing provisions cannot be applied because the application of ALP adjustment will indeed result in erosion of Indian tax base-...

Jurisdiction of Transfer Pricing Officer - Suo motu, TPO cannot take cognizance of any international transaction for suggesting adjustment in the arm’ s length price,...

TP Adjustment - Arm's Length Price (ALP) adjustment - The gross margins of assessee are much more than the gross margins of comparable companies chosen by the ld. TPO....

TP Adjustment - Determination of arm’s-length price - Law does not permit the TPO or DRP to determine the arm’s length price on estimation or adhoc basis. - Accordingly...

Quick Updates: