Transfer pricing adjustment - most appropriate method - CUP ...

CUP Method Rejected for Transfer Pricing; AO Directed to Use TNMM for Benchmarking International Transactions Margins.

February 14, 2019

Case Laws Income Tax AT

Transfer pricing adjustment - most appropriate method - CUP method was not correct method - AO directed to apply TNMM method to benchmark the international transactions of assessee and compare the margins shown by assessee with the mean margins of comparables which are functionally comparable.

View Source

← Previous Next →

Transfer pricing adjustment - most appropriate method - CUP ...

CUP Method Rejected for Transfer Pricing; AO Directed to Use TNMM for Benchmarking International Transactions Margins.

February 14, 2019

Case Laws Income Tax AT

You may also like:

Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for...

The Appellate Tribunal considered TP adjustment on brokerage commission received from related parties. It found TNMM method appropriate for benchmarking the commission...

The High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) which had approved the Comparable Uncontrolled Price (CUP) method adopted by the assessee for...

The High Court held that a change in the approach of assessing tax, without any statutory change, leads to uncertainty in cash flow and fund flow, which are crucial for...

The ITAT allowed the revenue's appeal for statistical purposes and remitted the matter back to the Assessing Officer to re-examine the issue and refer it to the Transfer...

TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net...

Transfer pricing - determination of ALP - selection of MAM - application of CUP method as against TNMM - AO/TPO directed first apply CUP using some comparable instances...

This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

ITAT adjudicated transfer pricing dispute regarding software development services benchmarking. The Tribunal comprehensively examined functional comparability, rejecting...

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 ITAT ruled in favor of the appellant regarding transfer pricing of electricity from its captive power plants to its cement unit. The Tribunal rejected the TPO's...

The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should...

ITAT addressed transfer pricing adjustment regarding business support services between associated enterprises. TPO rejected assessee's TNMM method and entity-level...

Transfer pricing adjustment - CUP method as the Most Appropriate Method for determination of ALP for international transactions. The assessee is also directed to...

ITAT remanded the transfer pricing (TP) adjustment matter relating to support services payment to AO for fresh consideration, finding that TPO erroneously rejected the...

Quick Updates: