TP Adjustment - intra group services - The assessee has failed ...

Income Tax

September 23, 2023

TP Adjustment - intra group services - The assessee has failed to completely demonstrate the Arm’s Length Price of intra group services by satisfying need test, benefit test, rendition test, duplicative test etc . We set aside the whole issue back to the file of AO/ TPO with a direction to the assessee to substantiate the Arm’s Length Price of the intra group services demonstrating the above tests / ingredients mentioned. - AT

View Source

← Previous Next →

TP Adjustment - intra group services - The assessee has failed ...

Income Tax

September 23, 2023

You may also like:

Transfer pricing adjustments - Location Savings and Imputation of mark-up on pass through costs - this intra-group services rendered by the assessee to the parent...

TPA - This is a case in which transfer pricing provisions cannot be applied because the application of ALP adjustment will indeed result in erosion of Indian tax base-...

TP Adjustment - ALP determination - intra-group services - TPO cannot stand in judgment on what benefits the assessee has derived from the services and assessee's...

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

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

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 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 - intra/group services in the nature of management services - DRP ignored the evidences filed by the assessee demonstrating receipt of management services...

Transfer Pricing Adjustment - Transfer Pricing Regulations do not contemplate taking into account future data for the purpose of bench marking - AT

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

Quick Updates: