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 April 2017 Year 2017 This

TPA - selection of comparables - challenging the approach of ...

Income Tax

April 26, 2017

TPA - selection of comparables - challenging the approach of bifurcating single transaction of marketing and after sales support service into the separate transaction of marketing support service and technical support service - AO/TPO directed to address the issues - AT

View Source

 


 

You may also like:

  1. 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...

  2. TPA - comparable selection - turnover filter application - turnover filter is one of the essential filter in order to select comparables when acted in same atmosphere -...

  3. 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...

  4. TP Adjustment - selection of MAM - CUP cannot be applied on basis of comparable uncontrolled transactions- internal or external- that are undertaken in different...

  5. TPA - One of the comparables Caliber Point Business Solutions has related party transactions of 30% of Revenue and going by the threshold filter of 25% of the related...

  6. TPA - comparable selection - companies with revenues less than 75% from software development services would be ideal to be excluded, as economic circumstances of such...

  7. TP Adjustment - Comparable selection - determination of the arm’s length price (ALP) of international transactions - The appellant contested the inclusion of two...

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

  9. TP adjustment - comparable selection - functinal dissimilarity - media content and TV broadcasting are totally dissimilar activities - not at all comparable - AO/ TPO to...

  10. TPA - comparable selection - substantial question of law - the Revenue has routinely brought such matters before this Court knowing fully well that the Transfer Pricing...

  11. TPA - selection of comparable - the companies having diminishing revenue should not be excluded, but, only the companies having persistent losses should be expelled from...

  12. Selection of comparable - TPA - a company cannot be selected as a comparable not only on the reason of failing employee cost filter, but also due to amalgamation during...

  13. Selection of comparables - TPA - There is an extra-ordinary event which resulted in high operating margin of that company – the AO is directed to exclude these companies...

  14. TP Adjustment - comparable selection - None of the comparables have been excluded on the ground of high turnover alone. The test of functional similarity applied by the...

  15. TP adjustment - comparable selection - RTP - the %age of RPT is determined based on the availability of comparables - The more we restrict, chances of loosing reasonable...

 

Quick Updates:Latest Updates