TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's ...

Income Tax

December 12, 2023

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) of a domestic transaction. If no Arm's Length Price is required to be determined, then, no reference was required to be made. - AT

View Source

← Previous Next →

TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's ...

Income Tax

December 12, 2023

You may also like:

TPA - ALP determination - Without complying to the statutory provisions, the Transfer Pricing Officer certainly cannot determine the arm's length price on ad-hoc /...

Transfer Pricing adjustments - Arms length price (ALP) - u/s 92CA - software development and IT enabled services - selection of comparable - Size matters in business

Transfer pricing adjustment deleted - the comparables adopted by the assessee are uncontrolled parties and can be considered for the purpose of determining the Arms'...

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...

Jurisdiction of Transfer Pricing Officer - Suo motu, TPO cannot take cognizance of any international transaction for suggesting adjustment in the arm’ s length price,...

TP - Arm's length price - CBDT instruction does not restrict the powers of the AO from making references to the Transfer Pricing Officer after 30th June 2003

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

Arms' length price adjustment - There is no reasoning and justification for applying the margins earned in trading activity to indenting activity as the two are distinct...

Determination of Arm’s Length Price – In the guise of determination of ALP, the TPO cannot question the business decision of payment and determine that no services were...

Quick Updates: