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1. TPA - the jurisdiction and power of TPO is to determine arm's length price of Royalty and the order of TPO holding that the assessee had not derived any benefit under...

2. The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

3. 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)...

4. 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...

5. Royalty receipts were subject to transfer pricing adjustment by TPO on basis of differences in amounts reflected in Form 3CEB of assessee vis-à-vis its group entities,...

6. If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

7. Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

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

9. 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...

10. The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

11. Valuation of imported goods - inter-se relation having any influence on the transaction value of imports, or not - If the price declared was at arm’s length, then...

12. Penalty u/s 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it...

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

14. Income Tax: TPO empowered to determine arm's length price for specified domestic transactions not referred by Assessing Officer or reported in audit report. Sections...

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