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 October 2018 Year 2018 This

Determination of arm's length price - Merely because the ...

Income Tax

October 24, 2018

Determination of arm's length price - Merely because the assessee is carrying on its business through different tools simply cannot make it non comparable, if the functions performed by them and various filters applied in accept/ reject matrix allows it to be included.

View Source

 


 

You may also like:

  1. 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...

  2. TP Adjustment - Determination of arm’s-length price - Law does not permit the TPO or DRP to determine the arm’s length price on estimation or adhoc basis. - Accordingly...

  3. 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...

  4. 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...

  5. Comparison - Arm’s length price – Comparability of price with the chosen company - assessee's contention that assessee is in merely functional advisory consultancy...

  6. TP Adjustment - determination of Arm's Length Price - intra group services transactions as Cross-charges - Documents submitted by the assessee do not conclusively...

  7. Taxability of income in India - Income attributable to India - income of advertisement and subscription revenue - Permanent Establishment (PE) - business connection -...

  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. TP Adjustment - reimbursement of expenses - Determining the arms length price as NIL - the assessee has not been able to prove the actual rendering of...

  10. 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...

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

  12. Determination of ALP – The business model of 50:50, as was admittedly prevalent in the line of business activity of the assessee and as is followed by the assessee, thus...

  13. TP adjustment - Determining the arms’ length value for sale of steam at Rs. “nil” - scope of the quotation obtained by the assessee from SSPL - the quotation obtained by...

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

  15. TP Adjustment to the licence fees paid for time and billing software - Determination of arm's length price at Nil in grounds 1 & 2 and at Rs. 50 lakhs on ad hoc basis in...

 

Quick Updates:Latest Updates