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1. 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)...

2. U/s 92C(2) of IT Act 1961- Computation of arm's length price - price variance upto 1% in case of wholesale trade and 3% in all other cases will be allowed.

3. If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

4. Computation of arm's length price - tolerance limit of 1% in case of wholesale trading and 3% in other cases notified - U/s 92C(2) of IT Act 1961 - Notification

5. U/s 92C(2) of IT Act 1961- Computation of arm's length price - specifies the tolerance limit in case of wholesale trading and other cases - Notification

6. TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's Length Price is required to be determined for a transaction with specified persons in section 40A(2)(b)...

7. Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

8. TPA - where the variation between the arm’s length price determined u/s 92C and the price at which the international transaction or specified domestic transaction has...

9. TP - Arm's length price - CBDT instruction does not restrict the powers of the AO from making references to the Transfer Pricing Officer after 30th June 2003

10. Computation of Arm’s length price - Selection of comparables by TPO –The foreign exchange fluctuations income cannot be excluded from the computation of the operating...

11. Transfer pricing - Computation of Arm's length price - Notified percentage under second proviso to section 92C(2) - Notification

12. Valuation of imported goods - inter-se relation having any influence on the transaction value of imports, or not - If the price declared was at arm’s length, then...

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

14. 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...

15. Revision u/s 263 by CIT - There is no such finding about the payment to the dependent agent being less than the arm’s length price of services rendered by the dependent...