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 August 2019 Year 2019 This

TP adjustment - Comparable selection - if finances of the three ...

Income Tax

August 3, 2019

TP adjustment - Comparable selection - if finances of the three comparables with reference to their respective annual reports, did show that there was a general trend in the industry of either loss-making or declining revenues and there was no dispute on the functional profile of the Assessee being similar with comparable then loss making companies should not be excluded only on that basis

View Source

 


 

You may also like:

  1. TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned...

  2. Transfer pricing adjustment - selection of comparable - Tribunal specified the aspects that may be kept in mind by the DRP while addressing the objections in respect to...

  3. Transfer pricing adjustment - selection of comparable - AO/TPO is directed to work out the ALP of the assessee with direction - AT

  4. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

  5. TP Adjustment - Reference to TPO - none of the two conditions enshrined in the Instruction of 2016 were satisfied in as much as neither transfer pricing adjustment of...

  6. Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

  7. TP Adjustments - AO does not have the jurisdiction to propose any transfer pricing adjustment in case where he has not made any reference to the TPO. Therefore the...

  8. TPA - determination of ALP - TP adjustment by applying Bright Line Test (BLT) is not sustainable on protective basis having no statutory mandate.

  9. Transfer pricing adjustment – export to associated enterprises of spares and components required for the purpose of servicing of vehicles sold by assessee - the...

  10. Transfer pricing adjustment – Guarantee charges for guarantee to AE – no upward adjustment in the ALP in relation to charging of guarantee commission over and above...

 

Quick Updates:Latest Updates