ITAT allowed taxpayer's appeal, rejecting transfer pricing ...

Transfer Pricing Appeal Succeeds: Internal Comparables Validated, Tax Adjustment of INR 30.2M Overturned Based on Profitability Analysis

May 21, 2025

Case Laws Income Tax AT

ITAT allowed taxpayer's appeal, rejecting transfer pricing adjustment of INR 30,264,835. The tribunal found merit in the argument that internal comparables should not be dismissed solely based on transaction volume. Referencing a prior Delhi HC decision, the tribunal held that comparable entities cannot be automatically rejected due to size disparity. The lower authorities erred in disqualifying the assessee's internal non-arm's length transaction profitability comparison. Consequently, the arm's length price (ALP) adjustment was deleted, affirming the taxpayer's transfer pricing methodology as justified.

View Source

← Previous Next →

ITAT allowed taxpayer's appeal, rejecting transfer pricing ...

Transfer Pricing Appeal Succeeds: Internal Comparables Validated, Tax Adjustment of INR 30.2M Overturned Based on Profitability Analysis

May 21, 2025

Case Laws Income Tax AT

You may also like:

Transfer pricing adjustment - primary responsibility to bench mark the transactions with comparable cases - the certificate issued by the auditors only spell out the...

Transfer pricing adjustment concerning comparability selection and attribution of profits between the respondent assessee and foreign Associated Enterprise. TPO rejected...

Transfer pricing Adjustments - ALP - Once internal comparable was available, along with the segmental details, TPO was required to examine the same and carry out the...

Transfer pricing adjustments - selection of internal comparables - TPO had no mandate to have recourse to external comparables when in the present case, internal...

TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...

HC held that Comparable Uncontrolled Price (CUP) method was appropriate for determining Arm's Length Price (ALP) for power transfer between eligible and non-eligible...

Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

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)...

Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections...

Transfer pricing adjustment - selection of comparable - Tribunal specified the aspects that may be kept in mind by the DRP while addressing the objections in respect to...

TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated...

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

TP Adjustment - Working capital adjustment - there is no need for making any negative working capital adjustment, when assessee does not carry on with any working...

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

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

Quick Updates: