Penalty u/s 271(1)(c) - TP addition - if the assessee computed ...

Income Tax

August 22, 2019

Penalty u/s 271(1)(c) - TP addition - if the assessee computed the ALP of the international transaction as per the manner prescribed in good faith and due diligence then simply because now there remains some difference in the manner of determination of the ALP, it cannot be held that the assessee either concealed the particulars of its income or furnished inaccurate particulars of income - no penalty

View Source

← Previous Next →

Penalty u/s 271(1)(c) - TP addition - if the assessee computed ...

Income Tax

August 22, 2019

You may also like:

Penalty u/s 271(1)(c) - price charged by the assessee in international transactions have not been computed in accordance with the provisions contained in section 92C -...

Addition towards adjustment of Arm’s Length Price - The seven sets of international transactions undertaken by the assessee cannot be considered as ‘closely linked’. - AT

Imposition of penalty u/s 271G - failure to furnish information or documents in respect of segmental amount relating to transaction made with AEs and non-AEs for...

TP Adjustment - arm’s length price (ALP) of the international transaction - The tinkering of PLI by substituting the denominator with total cost is unacceptable...

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)...

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'...

TP Adjustment - determination of arm’s length price, ALP - Transactions with the local vendors the terms of which are not influenced by Comer SpA cannot be treated as...

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...

Arm's Length Price adjustment on international transaction – selection of comparable - if abnormal loss making companies are excluded abnormal profit making companies...

Quick Updates: