Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights June 2023 Year 2023 This

TP adjustment - Determining the arms’ length value for sale of ...


Transfer Pricing Dispute: Arm's Length Value for Steam Sale at Nil Price Sent Back for Reassessment by Assessing Officer.

June 8, 2023

Case Laws     Income Tax     AT

TP adjustment - Determining the arms’ length value for sale of steam at Rs. “nil” - scope of the quotation obtained by the assessee from SSPL - the quotation obtained by the assessee is not backed by any analysis of the evaluation of the price so quoted and the said quotation is not supported by any supporting evidences. - Since appropriate exercise has not been conducted by the assessee to justify the arms length price of steam supplied to its associated enterprise, this issue is restored to the file of AO - AT

View Source

 


 

You may also like:

  1. If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

  2. The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

  3. ITAT adjudicated transfer pricing dispute regarding comparable company selection. The tribunal determined the Arm's Length Price (ALP) computation by the Transfer...

  4. ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely...

  5. The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

  6. Valuation of imported goods - inter-se relation having any influence on the transaction value of imports, or not - If the price declared was at arm’s length, then...

  7. Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

  8. ITAT adjudicated transfer pricing dispute involving manufacturing and service segments. Tribunal found substantial merit in assessee's contentions regarding arm's length...

  9. Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

  10. The Income Tax Appellate Tribunal held that the export commission paid by the assessee to foreign agents in Korea and Indonesia for sales, marketing, and customer...

  11. Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment...

  12. Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

  13. Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

  14. The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

  15. 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)...

 

Quick Updates:Latest Updates