Home Highlights December 2014 Year 2014 This

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1. 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...

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

3. TP adjustment - Intragroup services filed by the assessee from its AE - Either way when the Revenue seeks to disturb the Most Appropriate Method adopted by the assessee,...

4. 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,...

5. TP adjustment - ALP determination - Selection or change in Most Appropriate Method (MAM) - “Other Method" v/s "CUP Method" - Assessee can resile from the most...

6. TP adjustment - royalty paid by the assessee to its AE - selection of MAM - The method of the assessee can be pigeonholed in the “other method” provided in Rule 10AB r.w....

7. Penalty u/s 271G - assessee applied TNMM for determining of ALP - information/documents sought for determining of ALP as per CUP method - the difficulty in maintaining...

8. Transfer Pricing Adjustments - Selection of the most appropriate method (MAM) for determining the arm's length price (ALP) - The assessee's choice to adopt the 'other...

9. Transfer pricing (TP) adjustments - The method adopted by the TPO suffered from the defect of the comparing uncomparable chemicals, using an average variation between...

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

11. TP Adjustment - TPO arriving ALP by using TNMM Method and rejecting the CPM Method used by the appellant company for the purpose of determining ALP - In any case, the...

12. Adoption of Profit Level Indicator (PLI) of OP/TC to determine ALP - , in the absence of identification or segregation of capital employed with regard to AE's...

13. Transfer pricing (TP) adjustment - the learned TPO was not justified in comparing the gross margin in export segment vis-a-vis gross margins in domestic segment. - There...

14. The High Court held that a change in the approach of assessing tax, without any statutory change, leads to uncertainty in cash flow and fund flow, which are crucial for...

15. Transfer pricing - determination of ALP - selection of MAM - application of CUP method as against TNMM - AO/TPO directed first apply CUP using some comparable instances...