TP Adjustment - applicability of Section 144C(13) - As provided ...

Income Tax

January 6, 2021

TP Adjustment - applicability of Section 144C(13) - As provided in the Section 144C(13) of the Act, the final order of the Assessing Officer should be in conformity with the directions given by the DRP. In the present case, while working out the ALP adjustment, he has not followed the direction of the DRP, consequently, the assessment order is bad in law - AT

View Source

← Previous Next →

TP Adjustment - applicability of Section 144C(13) - As provided ...

Income Tax

January 6, 2021

You may also like:

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

TP adjustment - AO/TPO has not followed direction of DRP - As per section 144C(13) the AO is bound to pass the final assessment order in conformity with the direction of...

Transfer pricing adjustment - applicability of CUP to a single combined international transaction of Import of Crystal goods and Crystal components, cannot be considered...

Transfer pricing adjustment - The financial position and credit rating of the subsidiaries will be broadly the same as the holding company - domestic prime lending rate...

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

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

TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

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...

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...

Transfer pricing - Application of Section 144C - eligible assessee - Appellant contended that as the TPO has not prescribed any adjustment in the Transfer Pricing order....

Quick Updates: