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 March 2016 Year 2016 This

Adoption of Profit Level Indicator (PLI) of OP/TC to determine ...


Operating Profit to Total Cost Adopted for Arm's Length Price; RoCE Method Deemed Inappropriate for Margin Determination.

March 15, 2016

Case Laws     Income Tax     HC

Adoption of Profit Level Indicator (PLI) of OP/TC to determine ALP - , in the absence of identification or segregation of capital employed with regard to AE's transaction and those with others, the RoCE method would not indicate the appropriate margin for determining the ALP. - HC

View Source

 


 

You may also like:

  1. Royalty Benchmarking - assessee had adopted TNMM at the entity level in which process royalty payment is considered as closely linked transaction and part of operating...

  2. 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...

  3. 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...

  4. 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...

  5. Valuation - best judgment assessment - related person - where arm's length sales are made at well below cost, CESTAT is not justified in adopting cost plus method - SC

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

  7. This notification, issued u/s 92C(2) of the Income Tax Act 1961, specifies the tolerance range for variation between the arm's length price determined u/s 92C and the...

  8. Valuation of imported goods - inter-se relation having any influence on the transaction value of imports, or not - If the price declared was at arm’s length, then...

  9. Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

  10. TPA - where the variation between the arm’s length price determined u/s 92C and the price at which the international transaction or specified domestic transaction has...

  11. Upward adjustment on arm’s length price - selection of MAM - No infirmity in choosing the Cost Plus Method (CPM) by the assessee to determine the arm’s length price...

  12. TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's Length Price is required to be determined for a transaction with specified persons in section 40A(2)(b)...

  13. Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

  14. Computation of Profit Level Indicator (PLI), being, the Operating Profit/Total Cost (OP/TC) of the assessee -Like debts becoming bad from the sale of goods assuming the...

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

 

Quick Updates:Latest Updates