TP Adjustment - Rejection of Associated Enterprises as the ...

Income Tax

January 12, 2023

TP Adjustment - Rejection of Associated Enterprises as the tested party - foreign Associated Enterprises satisfied all the criteria for being taken as a tested party. TPO merely rejected the same as Associated Enterprises is located in different geographical locations. It a proper justification by the learned Transfer Pricing Officer to reject the foreign Associated Enterprises as a tested party. - CIT(A) order diciding the issue in favor of assessee is affirmed. - AT

View Source

← Previous Next →

TP Adjustment - Rejection of Associated Enterprises as the ...

Income Tax

January 12, 2023

You may also like:

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

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

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

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 - 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...

Transfer pricing adjustment - international transaction relating to acquisition of intangible assets by assessee from its associated enterprise - All the additions...

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

Transfer pricing adjustments - associated enterprise - the transactions between the assessee [ IJMII Integrated Township Development Co. Pvt. Ltd] and IJMII do not fall...

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

TP Adjustment - Receipt of royalty income from its associated enterprises - when the approach adopted by the assessee is found to be acceptable, the adjustment...

Quick Updates: