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 August 2017 Year 2017 This

When the transactions are multiple and inter-related then if a ...


Arm's Length Price: Avoid Separate Methods for Inter-Related Transactions When Comparable Uncontrolled Price Method Fails for One.

August 7, 2017

Case Laws     Income Tax     AT

When the transactions are multiple and inter-related then if a particular transaction out of the composite transactions cannot be tested under CUP then it is not proper to apply separate methods for determining the ALP for each of the transaction.

View Source

 


 

You may also like:

  1. 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...

  2. 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...

  3. 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...

  4. The ITAT determined that the Transactional Net Margin Method (TNMM) was the most appropriate method for benchmarking international goods sale/export transactions,...

  5. Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

  6. 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...

  7. 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...

  8. The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

  9. 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)...

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

  11. ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal found that tax authorities erroneously rejected the Transactional Net...

  12. Imposition of penalty u/s 271G - failure to furnish information or documents in respect of segmental amount relating to transaction made with AEs and non-AEs for...

  13. ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal upheld the TPO's rejection of the assessee's transfer pricing study,...

  14. The ITAT held that the Transfer Pricing Officer (TPO) should consider comparables dealing in electronic products only, supported by a technical expert's certificate,...

  15. Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

 

Quick Updates:Latest Updates