ALP of the international transaction of payment of Fees for ...

Income Tax

June 29, 2019

ALP of the international transaction of payment of Fees for Management services - 5% mark-up under Cost plus method - Even if, we proceed with the assumption that the mark up of 5% is not at ALP, which should be as low as 1% or even less than that, still the difference arising on account of such mark-up going even up to 0% in a comparable uncontrolled situation, would be within +/-5% range, not requiring any TP adjustment

View Source

← Previous Next →

ALP of the international transaction of payment of Fees for ...

Income Tax

June 29, 2019

You may also like:

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

TP Adjustment - Upward adjustment of Arm’s Length Price in respect of Management Services - These services are not in the nature of stewardship or shareholder activity....

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

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...

TP Adjustment - excessive AMP expenses - third party also benefits - Revenue also could not demonstrate the presence of any machinery provision to compute Arm’s Length...

TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the...

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 - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

Upward adjustment on arm’s length price - selection of MAM - No infirmity in choosing the Cost Plus Method (CPM) by the assessee to determine the arm’s length price...

Quick Updates: