Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights October 2015 Year 2015 This

TPA - Benchmarking international transactions with its associate ...

Case Laws     Income Tax

October 21, 2015

TPA - Benchmarking international transactions with its associate enterprises on aggregate basis, TNMM method should be applied and since the margins declared by the assessee are higher than the margins declared by the comparables picked up by the assessee in its TP study report - AT

View Source

 


 

You may also like:

  1. TP Adjustment - tested party - No infirmity in the order of the learned CIT(A) in directing the assessee to adopt the foreign associated enterprise as tested party with...

  2. Transfer pricing adjustment – When the indent/commission transaction with the associated enterprises is to be benchmarked, the same should be done with indent/...

  3. TP Adjustment - As per the provisions of aforesaid Rule, the ‘other method’ shall be the method which takes into account the price which has been or would have been...

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

  5. TP adjustment - onsite development and project coordination fee’ - Associated enterprise can be considered as a tested party, in the present case. Accordingly, we direct...

  6. TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from...

  7. Transfer pricing adjustment - arm‘s length pricing of international transactions - Advertising / Marketing and Promotion Expenses - international transaction - Domestic...

  8. TPA - even if it could be treated as a corporate guarantee for benchmarking purposes, the corporate guarantee does not constitute an international transaction under...

  9. TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the...

  10. Transfer pricing adjustment - international transaction relating to acquisition of intangible assets by assessee from its associated enterprise - All the additions...

  11. Corporate Guarantee or Letter of Comfort given by the assessee to its Associate Enterprise does not involve any cost to the assessee, therefore, it was outside the ambit...

  12. TP Adjustment - Receipt of royalty income from its associated enterprises - when the approach adopted by the assessee is found to be acceptable, the adjustment...

  13. TP Adjustment - The Legislature has never shown an intention to treat the same international transaction in two different ways in the hands of two associated enterprises...

  14. TPA - receivables forming a part of international transaction - TPO is not justified in concluding that the figure of receivables beyond 180 days constitutes an...

  15. TP Adjustment - international transactions u/s. 92B or not - In absence on any such agreement, the first and primary condition of holding the transaction in question as...

 

Quick Updates:Latest Updates