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 September 2013 Year 2013 This

Transfer pricing Adjustments - ALP - Once internal comparable ...

Case Laws     Income Tax

September 7, 2013

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 comparability analysis. It is only when internal TNMM fails, the TPO can go into search for external TNMM because external comparable require lot of functionality test and adjustments - AT

View Source

 


 

You may also like:

  1. 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...

  2. Transfer Pricing adjustments - Arms length price (ALP) - u/s 92CA - software development and IT enabled services - selection of comparable - Size matters in business

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

  4. TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

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

  6. Transfer pricing adjustment - determination of ALP - Not only changing the tested party from the assessee to its AE, the CIT (Appeals) has also selected a domestic...

  7. TP Adjustment - Arm's Length Price (ALP) adjustment - The gross margins of assessee are much more than the gross margins of comparable companies chosen by the ld. TPO....

  8. TPA - This is a case in which transfer pricing provisions cannot be applied because the application of ALP adjustment will indeed result in erosion of Indian tax base-...

  9. Transfer pricing adjustment - selection of comparable - AO/TPO is directed to work out the ALP of the assessee with direction - AT

  10. Comparable selection for determining arm's length price (ALP) adjustment. Appeals limited to including or excluding certain uncontrolled entities as comparables...

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

  12. TP Adjustment - MAM - Considering brokerage rate of all Non-AEs for the comparability purposes - Arm's Length Price (ALP) of broking commissions - The Tribunal directed...

  13. Tribunal held that Vishal Information Technologies Ltd. and Nucleus Net soft & GIS (India) Ltd. should be excluded from comparable selection for determining arm's length...

  14. The Appellate Tribunal examined Transfer Pricing Adjustment disallowing cost of support services. The cost allocation key based on 'headcount' was accepted by the...

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

 

Quick Updates:Latest Updates