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 May 2025 Year 2025 This

ITAT adjudicated multiple tax-related issues, primarily focusing ...


Tax Tribunal Rejects Transfer Pricing Method, Upholds Income Computation Disallowance and Project Provision Ruling

May 5, 2025

Case Laws     Income Tax     AT

ITAT adjudicated multiple tax-related issues, primarily focusing on transfer pricing and income computation. The Tribunal rejected the Transfer Pricing Officer's Cost Plus Method (CPM) for benchmarking international transactions, following precedent from previous years. The Tribunal upheld the disallowance of double deduction arising from actuarial valuation gain, sustaining the Revenue's position. Regarding project provision cost, the Tribunal dismissed the Revenue's appeal, maintaining the Commissioner of Income Tax (Appeals) original finding. The decision comprehensively addressed technical tax computation matters, predominantly favoring procedural and methodological consistency in income assessment.

View Source

 


 

You may also like:

  1. The High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) which had approved the Comparable Uncontrolled Price (CUP) method adopted by the assessee for...

  2. 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...

  3. This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

  4. ITAT adjudicated transfer pricing dispute involving international transactions between an assessee and its Associate Enterprise. The tribunal upheld the transfer pricing...

  5. Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

  6. Tribunal's conclusion that Resale Price Method (RPM) is the most appropriate method upheld. Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) had...

  7. The High Court held that a change in the approach of assessing tax, without any statutory change, leads to uncertainty in cash flow and fund flow, which are crucial for...

  8. ITAT adjudicated transfer pricing dispute involving Integrated Global Services (IGS) provided by Associated Enterprises. After comprehensive review of cost benefit...

  9. The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

  10. ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal upheld the TPO's rejection of the assessee's transfer pricing study,...

  11. Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

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

  13. The ITAT allowed the assessee's appeal regarding transfer pricing adjustments for power supply, ruling that the assessee's method for determining arm's length price was...

  14. ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal found that tax authorities erroneously rejected the Transactional Net...

  15. The ITAT Ahmedabad addressed Transfer Pricing (TP) adjustments, focusing on royalty, management fees, and IT allocation costs. The tribunal upheld the use of the...

 

Quick Updates:Latest Updates