TP Adjustment - tested party - No infirmity in the order of the ...

CIT(A) approves using foreign associated enterprise as tested party; advises against aggregating transactions for benchmarking. Excludes certain services.

September 7, 2022

Case Laws Income Tax AT

TP Adjustment - tested party - No infirmity in the order of the learned CIT(A) in directing the assessee to adopt the foreign associated enterprise as tested party with respect to 1st set of transactions, not to aggregate the first set of transaction and second set of transactions for benchmarking, exclusion of e–clerk services limited and TCS e–serve international Limited for benchmarking second set of transactions. - AT

View Source

← Previous Next →

TP Adjustment - tested party - No infirmity in the order of the ...

CIT(A) approves using foreign associated enterprise as tested party; advises against aggregating transactions for benchmarking. Excludes certain services.

September 7, 2022

Case Laws Income Tax AT

You may also like:

TP Adjustment - Rejection of Associated Enterprises as the tested party - foreign Associated Enterprises satisfied all the criteria for being taken as a tested party....

TP adjustment - onsite development and project coordination fee’ - Associated enterprise can be considered as a tested party, in the present case. Accordingly, we direct...

The ITAT Mumbai held that the Transfer Pricing Officer (TPO) unjustifiably rejected the benchmarking analysis done by the assessee for determining the Arm's Length Price...

TP adjustment - tested party - As per Guidance Note on report u/s 92E and transfer pricing guidelines issued by the OECD and united nation practical manual of transfer...

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

The High Court's decision addressed two key issues: disallowance of goodwill amount written off and transfer pricing adjustment. Regarding goodwill, the court held that...

The ITAT upheld the order of the CIT(A) regarding the Transfer Pricing (TP) adjustment. The Tribunal concurred with the CIT(A)'s decision to exclude two companies with...

TP adjustment - Benchmarking of interest on interest free advances good to the subsidiary companies - In the present case, the cost borrowing of the assessee does not...

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 – When the indent/commission transaction with the associated enterprises is to be benchmarked, the same should be done with indent/...

This notification amends the export policy condition for cough syrup under Chapter 30 of Schedule-II (Export Policy) of ITC (HS) 2022. The existing policy mandated...

TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated...

Disallowance of sales commission paid to two Associated Enterprises (AEs) being foreign entities - assessee failed to discharge the onus of proving legitimate business...

TP Adjustment - ALP of interest on NDC’s [Non-convertible debentures] - NCD issued to associated enterprise is unsecured and loans taken from third parties are secured...

Quick Updates: