Transfer pricing - arm's length price - Selection of comparable ...

Income Tax

June 4, 2012

Transfer pricing - arm's length price - Selection of comparable - Other enterprises have claimed depreciation at much lower amounts. Size of the assets besides the age of the assets of comparables was leading to difference in the profit margins and in mean margin. - Adjustment is required to be made - AT

View Source

← Previous Next →

Transfer pricing - arm's length price - Selection of comparable ...

Income Tax

June 4, 2012

You may also like:

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

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from...

Transfer Pricing – Arm Length Price – selection of comparables - assessee is not estopped from pointing out a mistake in the assessment. - AT

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...

Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

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

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...

Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The...

Arm's Length Price adjustment on international transaction – selection of comparable - if abnormal loss making companies are excluded abnormal profit making companies...

TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...

Transfer pricing adjustment - No need for provision of +/- 5% range for CPM of the arm's-length price as there are no comparable prices in the instant case providing a...

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

Penalty u/s 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it...

Transfer pricing adjustment - determining ALP - Assessing Officer was thus in error not only in resorting to an unscientific and unrecognized method ascertaining the...

Quick Updates: