Home Highlights June 2015 Year 2015 This

You may also like:

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

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

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

4. 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...

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

6. Transfer pricing - arm's length price - Selection of comparable - Other enterprises have claimed depreciation at much lower amounts. Size of the assets besides the age...

7. TP Adjustment - comparable selection - The ITAT that the turnover filter cannot be applied as a tool for cherry picking the comparables at the later stage after...

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

9. Transfer pricing adjustment - selection of comparable - Tribunal specified the aspects that may be kept in mind by the DRP while addressing the objections in respect to...

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

11. Transfer pricing adjustment to international transactions - Non-satisfaction of conditions prescribed u/r 10B(4) for using multiple year data. Assessee required to...

12. TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated...

13. TP Adjustment - comparable selection - filters applied by Ld.TPO - assessee is not involved in any of the strategic functions and is only undertaking preliminary...

14. TP Adjustment - comparable selection - ALP which is worked out after applying the 5% range - Application of Tolerance Range - The ITAT found that the CIT(A) correctly...

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