Home Highlights August 2015 Year 2015 This

You may also like:

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

2. TP Adjustment - Reference to TPO - none of the two conditions enshrined in the Instruction of 2016 were satisfied in as much as neither transfer pricing adjustment of...

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

4. 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...

5. Transfer pricing adjustment - TPO has rightly rejected the use of earlier year’s data by the assessee, as the assessee failed to establish how such earlier year’s data...

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

7. 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)...

8. 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) -...

9. This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

10. Capital Gain - Transfer u/s 2(47)(v) - assessment year - AO himself has given credit for the amount of capital gains declared for the assessment year 2013-14, while...

11. TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

12. Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

13. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

14. 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...

15. The High Court upheld the Income Tax Appellate Tribunal's (ITAT) decision regarding the applicability of Section 92(3) in determining the arm's length price for...