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1. 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...

2. 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)...

3. Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

4. Addition on account of share application and share premium money u/s 68 - assessee has received share application and share premium money from eleven investor companies...

5. 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)...

6. Computation of Arm’s length price - Selection of comparables by TPO –The foreign exchange fluctuations income cannot be excluded from the computation of the operating...

7. 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...

8. U/s 92C(2) of IT Act 1961- Computation of arm's length price - price variance upto 1% in case of wholesale trade and 3% in all other cases will be allowed.

9. Transfer pricing - Computation of Arm's length price - Notified percentage under second proviso to section 92C(2) - Notification

10. 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...

11. TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

12. Addition u/s 68 - unexplained cash credit in the form of share capital with premium - when all these corporate entities are still existing and doing business and have...

13. The High Court upheld the Income Tax Appellate Tribunal's (ITAT) decision regarding the applicability of Section 92(3) in determining the arm's length price for...

14. Addition u/s 68 - share application money/share capital and share premium as unexplained - The onus was on revenue to dislodge assessee’s documentary evidences and rebut...

15. 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...