TPA - CIT(A) has examined the agency agreement and held that ...

Case Laws Income Tax

June 23, 2015

TPA - CIT(A) has examined the agency agreement and held that that certain adjustments on account of functional differences between a person who acts as ‘principal to principal’ i.e. a trader and a person who acts as a mere ‘commission agent would be allowed - order of CIT(A) sustained - AT

View Source

← Previous Next →

TPA - CIT(A) has examined the agency agreement and held that ...

Case Laws Income Tax

June 23, 2015

You may also like:

ALP - The authorities have out rightly denied the adjustment on account of difference in capacity utilization –the AO/TPO is directed to verify the details and allow the...

TP Adjustment - Working capital adjustment - Making a working capital adjustment is an attempt to adjust for the differences in time value of money between the tested...

TP Adjustment - Notional Interest on Outstanding Receivables - While acknowledging that receivables from AEs constitute an international transaction, the tribunal held...

TP Adjustment - secondment of employees by Assessee to its AE - the benchmarking done by the TPO by applying the same rate of thirty party placement agency is not...

Addition u/s. 41(1) - Difference between the amount payable as per books of accounts and amount as per the confirmation received from the creditor - The High Court...

Difference on account of exchange rate fluctuation is entitled to deduction under section 80IB - AT

Payment of excess duty wrongly - Adjustment of the accounts from Head of Account BED to Head of account SED - It would be too harsh to not allow the prayer of the...

TP adjustment on account of back-to-back counter bank guarantee - TPO, by considering the rate charged by Bank of Baroda for issuance of guarantee against 100% counter...

TP Adjustment - Comparable selection - determination of arm’s length prices (ALP) - The High Court observed that the dissimilarity in products sold and their respective...

Transfer pricing - selection of comparable - Capacity adjustment to account for differences in capacity utilization of the Appellant vis-à-vis the comparable -...

TP Adjustment - Adjustment on account of working capital adjustment - Guidance on comparability adjustments is found in paragraphs 3.47-3.54 and in the Annexure to...

Addition on account of non-reconciliation of Form 26AS - business of advertisement agency - the assessee reports only the commission portion as its income in its P & L...

The assessee, a software solution provider, contested various transfer pricing adjustments and disallowances. Key points: Certain comparables were directed to be...

Transfer pricing adjustment - No interest having been charged by the assessee to the non-AE outstandings, its transaction of outstanding receivables with AE without...

TP Adjustment - MAM Adjustment - ALP adjustment -In TNMM what is to be seen is the functional comparability and not the product comparability. Further, it is observed...

Quick Updates: