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 June 2013 Year 2013 This

TP - the conclusion of the TPO that the arms length price of ...

Case Laws     Income Tax

June 27, 2013

TP - the conclusion of the TPO that the arms length price of the royalty payment should be NIL without specifying any cogent basis is not sustainable - TPO's determination is on the basis of assumption and surmises. - AT

View Source

 


 

You may also like:

  1. TP Adjustment - Equipment would not have been imported at NIL price even in an independent scenario. Moreover, we do not find that the TPO has applied any method to...

  2. TP Adjustment - reimbursement of expenses - Determining the arms length price as NIL - the assessee has not been able to prove the actual rendering of...

  3. 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...

  4. 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)...

  5. 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...

  6. 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)...

  7. 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...

  8. TP Adjustment - determination of Arm's Length Price - intra group services transactions as Cross-charges - Documents submitted by the assessee do not conclusively...

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

  10. Royalty Benchmarking - assessee had adopted TNMM at the entity level in which process royalty payment is considered as closely linked transaction and part of operating...

  11. TP Adjustment - regional management services received by the assessee - incorrect factual observations and invalid of assumption of jurisdiction by the TPO who without...

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

  13. 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...

  14. The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) Adjustment where the Transfer Pricing Officer (TPO) determined the Arm's Length Price...

  15. TPA - where the variation between the arm’s length price determined u/s 92C and the price at which the international transaction or specified domestic transaction has...

 

Quick Updates:Latest Updates