TP adjustment - The TPO has not given any reason as to why he ...

TPO's Adjustments Rejected: Export Division's Higher Profit Margin Confirms Transactions at Arm's Length, No TP Adjustment Needed. 'sLength.

December 28, 2020

Case Laws Income Tax AT

TP adjustment - The TPO has not given any reason as to why he altered the aggregate amount of Net profit. Hence the workings made by TPO is liable to rejected. We have noticed that the net profit margin worked out by the assessee in "Domestic - Personal care division" was 12.31%. The net profit margin worked out for "Exports to AEs" was 24.03%. Hence the net profit margin earned in the exports to AEs division is higher than its comparable "Domestic - Personal care division". Hence it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT

View Source

← Previous Next →

TP adjustment - The TPO has not given any reason as to why he ...

TPO's Adjustments Rejected: Export Division's Higher Profit Margin Confirms Transactions at Arm's Length, No TP Adjustment Needed. 'sLength.

December 28, 2020

Case Laws Income Tax AT

You may also like:

TP Adjustment - goods sold to Associated Enterprises (AEs) - NP Determination - The TPO has not given any reason as to why he did not consider above said two expenses...

Transfer pricing adjustment - adjustment in respect of international transaction relating to export of manufactured IC engines by considering the difference in the gross...

Assessment u/s 144 -profit margins, could be varied and disturbed only if the profit margins of other assesses engaged in similar business are higher

Adjustment towards foreign exchange fluctuation - non-consideration of impact of abnormal movement in the foreign exchange rates while computing the operating profit...

TP Adjustment - Arm's Length Price (ALP) adjustment - The gross margins of assessee are much more than the gross margins of comparable companies chosen by the ld. TPO....

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...

Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

Since the operating profit to cost margin of the appellant at 9.26% is higher than the operating profit to cost ratio of the comparable companies at 6.30%, the...

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 (TP) adjustment - the learned TPO was not justified in comparing the gross margin in export segment vis-a-vis gross margins in domestic segment. - There...

TP Adjustment - re-computation of ALP by combining both Import of material and Export of Finished goods and applying TNMM and thereby upward adjustment - The order of...

Transfer pricing adjustment to international transactions - Non-satisfaction of conditions prescribed u/r 10B(4) for using multiple year data. Assessee required to...

Transfer pricing adjustment – Since the profit margin of the assessee after taking into consideration the DEPB benefit as part of its turnover comes to 12.30% as against...

ITAT examined unverifiable purchases from 22 parties where assessee failed to provide conclusive proof. While books of accounts were accepted by AO and historical gross...

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...

Quick Updates: