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Income Tax - Highlights / Catch Notes

Home Highlights October 2015 Year 2015 This

CBDT notifies New Rule 10CA for Computation of arm's length ...

Income Tax

October 21, 2015

CBDT notifies New Rule 10CA for Computation of arm's length price in certain cases with detailed Illustrations - Notification

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  1. Computation of arm's length price - tolerance limit of 1% in case of wholesale trading and 3% in other cases notified - U/s 92C(2) of IT Act 1961 - Notification

  2. Transfer pricing - Computation of Arm's length price - Notified percentage under second proviso to section 92C(2) - Notification

  3. TP - Arm's length price - CBDT instruction does not restrict the powers of the AO from making references to the Transfer Pricing Officer after 30th June 2003

  4. U/s 92C(2) of IT Act 1961- Computation of arm's length price - specifies the tolerance limit in case of wholesale trading and other cases - Notification

  5. U/s 92C(2) of IT Act 1961- Computation of arm's length price - price variance upto 1% in case of wholesale trade and 3% in all other cases will be allowed.

  6. If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

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

  8. 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...

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

  10. Comparison - Arm’s length price – Comparability of price with the chosen company - assessee's contention that assessee is in merely functional advisory consultancy...

 

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