Transfer pricing adjustment - Reworking of the operating margin ...

Transfer Pricing Case: Operating Margin Reworking Requires Cost Apportionment by Man-Hour, Not Turnover Basis.

November 16, 2015

Case Laws Income Tax AT

Transfer pricing adjustment - Reworking of the operating margin - apportionment of cost has to be done on man-hour basis and not on turnover basis - AT

View Source

← Previous Next →

Transfer pricing adjustment - Reworking of the operating margin ...

Transfer Pricing Case: Operating Margin Reworking Requires Cost Apportionment by Man-Hour, Not Turnover Basis.

November 16, 2015

Case Laws Income Tax AT

You may also like:

Transfer pricing adjustment - in arriving at the operating cost in transfer pricing matters the principles of Cost Accounting will not be strictly applicable where cost...

Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated...

Valuation - includability or otherwise of the value of the free-of- cost components - Normally, the cost price of a product would take into account the purchase cost of...

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

TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net...

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...

Adjustment towards foreign exchange fluctuation - non-consideration of impact of abnormal movement in the foreign exchange rates while computing the operating profit...

Transfer pricing adjustment - TNMM method required comparison of net profit margin realized from international transactions or aggregate of international transactions...

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)...

TPA - 'operating profit’ from the international transaction is compared with the operating profit margin of the comparables under the TNMM. Thus the addition based on...

Transfer pricing adjustments - TPO directed to take into account 30% additional cost base to account "free of cost" material and revised the OP/TC margin of 13.65% for...

The ITAT held that the Transfer Pricing Officer's order was barred by limitation as it was not passed within 60 days from the date of the final assessment order as...

This case deals with transfer pricing adjustments made by the tax authorities regarding international transactions involving sale of Paclitaxel, Disodium Pamidronate,...

Levy of GST - Valuation - determination of margin - old and used motor vehicles - claim of deduction of cost incurred on refurbishment from the margin - It is noticed...

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) -...

Quick Updates: