Reopening of assessment - Since the impugned notice for the ...

Reassessment Notice Overturned: Arm's Length Price Procedure Followed, No Permanent Establishment in India Found.

May 3, 2018

Case Laws Income Tax SC

Reopening of assessment - Since the impugned notice for the reassessment is based only on the allegation that the appellant(s) has permanent establishment in India, the notice cannot be sustained once arm's length price procedure has been followed. - SC

View Source

← Previous Next →

Reopening of assessment - Since the impugned notice for the ...

Reassessment Notice Overturned: Arm's Length Price Procedure Followed, No Permanent Establishment in India Found.

May 3, 2018

Case Laws Income Tax SC

You may also like:

Review of order - originally held that since the impugned notice for the reassessment is based only on the allegation that the appellant(s) has permanent establishment...

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...

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...

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)...

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)...

Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

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...

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

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...

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

The High Court upheld the Income Tax Appellate Tribunal's (ITAT) decision regarding the applicability of Section 92(3) in determining the arm's length price for...

Income taxable in India - PE in India - Once we hold that in the light of the present legal position, existence of dependent agency permanent establishment in wholly tax...

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: