Determination of arm’s length price (ALP) - TPA - working ...

Transfer Pricing Analysis: Working Capital Adjustments Needed for Accurate Arm's Length Price, Regardless of Outcome.

October 8, 2015

Case Laws Income Tax AT

Determination of arm’s length price (ALP) - TPA - working capital adjustment has to be allowed based on the working capital requirements of the assessee and the comparable companies irrespective of the fact, whether such adjustment is negative or positive. - AT

View Source

← Previous Next →

Determination of arm’s length price (ALP) - TPA - working ...

Transfer Pricing Analysis: Working Capital Adjustments Needed for Accurate Arm's Length Price, Regardless of Outcome.

October 8, 2015

Case Laws Income Tax AT

You may also like:

TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned...

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely...

TP Adjustment - Working capital adjustment - there is no need for making any negative working capital adjustment, when assessee does not carry on with any working...

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

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...

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)...

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

Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment...

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...

Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The...

The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

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

Quick Updates: