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 November 2017 Year 2017 This

Clubbing of income for Arm’s Length Price (ALP) determination - ...

Income Tax

November 10, 2017

Clubbing of income for Arm’s Length Price (ALP) determination - clubbing of two distinct revenue streams - whether to segregate or not segregate two transactions, is entirely a fact dependent exercise that cannot per se be treated as a question of law. - HC

View Source

 


 

You may also like:

  1. Arms' length price adjustment - There is no reasoning and justification for applying the margins earned in trading activity to indenting activity as the two are distinct...

  2. Determination of Arm’s Length Price – In the guise of determination of ALP, the TPO cannot question the business decision of payment and determine that no services were...

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

  4. Transfer Pricing adjustments - Arms length price (ALP) - u/s 92CA - software development and IT enabled services - selection of comparable - Size matters in business

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

  6. Valuation - clearance of pipes - inter-connected undertakings - arms length price - Rule 10 (a) would apply only if such clause is specified in the Show Cause Notice...

  7. Arm Length Price (ALP) - Interest free loans to the sister concern by the Assessee-company - AE's who are 100% subsidiaries - The appropriate rate would be LIBOR plus 2% - AT

  8. 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)...

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

  10. Determination of Arm's Length Price - Marketing agent arrangement –TPO was right in adding a markup as not independent and prudent entrepreneur will provide any service...

 

Quick Updates:Latest Updates