Home Highlights April 2016 Year 2016 This

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1. Transfer Pricing Adjustments - Selection of the most appropriate method (MAM) for determining the arm's length price (ALP) - The assessee's choice to adopt the 'other...

2. TP adjustment - royalty paid by the assessee to its AE - selection of MAM - The method of the assessee can be pigeonholed in the “other method” provided in Rule 10AB r.w....

3. TP Adjustment - selection of most appropriate method (MAM) - Resale Price Method or Transactional Net Margin Method - Introduction of Fresh Comparables - Removal of 3%...

4. TP Adjustment - Selection of MAM - transactional net margin method is the most appropriate method, the TPO is directed to examine the international transactions entered...

5. Transfer pricing adjustment - most appropriate method - CUP method was not correct method - AO directed to apply TNMM method to benchmark the international transactions...

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

7. 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...

8. TP Adjustment - selection of MAM [Most Appropriate Method] - The High Court upheld the Tribunal's decision, affirming TNMM as the appropriate method for benchmarking...

9. TP Adjustment - Benchmarking of interest receivable on loan - when the assessee has charged higher interest on loan to subsidiary compared to the prevailing interest...

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

11. TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated...

12. IT - TP - Selection of comparable transactions - the selection of comparables and selection of similar transactions is not easy to find out and a difficult task to pick...

13. Transfer pricing adjustment - adoption of most appropriate method - selection of comparable - even if the export incentives entitlement is excluded from the operating...

14. Transfer pricing - determination of ALP - selection of MAM - application of CUP method as against TNMM - AO/TPO directed first apply CUP using some comparable instances...

15. Transfer pricing (TP) adjustments - The method adopted by the TPO suffered from the defect of the comparing uncomparable chemicals, using an average variation between...