Transfer pricing adjustment - ALP - selection of comparables - ...

Income Tax

June 23, 2015

Transfer pricing adjustment - ALP - selection of comparables - The risk undertaken and the assets employed by a software development company cannot be compared to a BPO company. - AT

View Source

← Previous Next →

Transfer pricing adjustment - ALP - selection of comparables - ...

Income Tax

June 23, 2015

You may also like:

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

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...

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

Arm's Length Price adjustment on international transaction – selection of comparable - if abnormal loss making companies are excluded abnormal profit making companies...

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-...

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 adjustment - selection of comparable - AO/TPO is directed to work out the ALP of the assessee with direction - AT

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

Quick Updates: