TP Adjustment - Comparable selection - determination of arm’s ...

Income Tax

March 21, 2024

TP Adjustment - Comparable selection - determination of arm’s length prices (ALP) - The High Court observed that the dissimilarity in products sold and their respective turnovers could significantly impact the profitability of an entity. Despite acknowledging significant differences and accepting the appellant's arguments, the ITAT failed to entirely exclude Modicare. The Court considered this a vital infirmity and directed the ITAT to re-examine the appropriateness of including Modicare and the functional difference in marketing strategy between the entities.

View Source

← Previous Next →

TP Adjustment - Comparable selection - determination of arm’s ...

Income Tax

March 21, 2024

You may also like:

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

TP Adjustment - Comparable selection - determination of the arm’s length price (ALP) of international transactions - The appellant contested the inclusion of two...

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

TP Adjustment - Arm's Length Price (ALP) adjustment - The gross margins of assessee are much more than the gross margins of comparable companies chosen by the ld. TPO....

TP Adjustment - determination of arm’s length price, ALP - Transactions with the local vendors the terms of which are not influenced by Comer SpA cannot be treated as...

TP Adjustment - comparable selection - The ITAT that the turnover filter cannot be applied as a tool for cherry picking the comparables at the later stage after...

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)...

TP Adjustment - MAM - Considering brokerage rate of all Non-AEs for the comparability purposes - Arm's Length Price (ALP) of broking commissions - The Tribunal directed...

TP Adjustment - determination of Arm’s Length Price (ALP) - The products are unique and not comparable to others. The terms and conditions and the economic circumstances...

TP adjustment - Determining the Arm's Length Price of international transactions in respect of "advisory services" - we adopt judicial consistency in the absence of any...

Arm's Length Price adjustment on international transaction – selection of comparable - if abnormal loss making companies are excluded abnormal profit making companies...

TP Adjustment - Determination of arm’s-length price - Law does not permit the TPO or DRP to determine the arm’s length price on estimation or adhoc basis. - Accordingly...

TP Adjustment - Determination of Arms Length Price (ALP) - Once a particular expenditure itself is disallowed, there can be no question of including it in the Operating...

Upward adjustment on arm’s length price - selection of MAM - No infirmity in choosing the Cost Plus Method (CPM) by the assessee to determine the arm’s length price...

TP - Re-computation of arms' length price (ALP). - selection of comparable - no opportunity of being heard was provided to the assessee for rebuttal, therefore the...

Quick Updates: