Transfer pricing adjustments - the comparables could not be ...

Loss-Making Comparables in Transfer Pricing Adjustments Valid Unless Extraordinary Factors Affect Transaction's Comparability.

August 27, 2013

Case Laws Income Tax AT

Transfer pricing adjustments - the comparables could not be rejected only on the ground of loss making unless the losses are because of some extraordinary factors which have affected the comparability of the transaction. - AT

View Source

← Previous Next →

Transfer pricing adjustments - the comparables could not be ...

Loss-Making Comparables in Transfer Pricing Adjustments Valid Unless Extraordinary Factors Affect Transaction's Comparability.

August 27, 2013

Case Laws Income Tax AT

You may also like:

Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

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

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...

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

Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

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 (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

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

Arm's Length Price adjustment on international transaction – selection of comparable - if abnormal loss making companies are excluded abnormal profit making companies...

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...

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

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)...

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...

Transfer pricing adjustment - TPO made an adjustment taking in to consideration the OP/OC for AE segment at 23% [26%(-)3%,an allowance for delay in receivables and after...

Quick Updates: