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 December 2015 Year 2015 This

TPA - TPO confused himself in characterization of the assessee's ...

Case Laws     Income Tax

December 27, 2015

TPA - TPO confused himself in characterization of the assessee's functions as captive, routine, full-fledged distributor at one place and routine distributor in another place. The Transfer Pricing Officer is also characterizing the assessee as an agent in one place and captive distributor and agent in another place - matter remanded back - AT

View Source

 


 

You may also like:

  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. There is inconsistency in adjudicating the assessee's functional profile. The Tribunal treated the assessee as TPO/KPO for certain years but as a non-KPO/ITeS for...

  3. TP Adjustment - the Ld.TPO has observed that the services rendered by the assessee are under two segments, but still holds the services of the assessee under SWD segment...

  4. TP Adjustment - risk based assessment and selection of comparable - The glaring fallacy in the approach of the TPO lies on the fact that he has adopted FOB cost of goods...

  5. TP Adjustment - comparable selection - filters applied by Ld.TPO - assessee is not involved in any of the strategic functions and is only undertaking preliminary...

  6. TPA - the jurisdiction and power of TPO is to determine arm's length price of Royalty and the order of TPO holding that the assessee had not derived any benefit under...

  7. TP adjustment - Adjustment made by the TPO on the value of electricity supplied by the Captive Power Plant (CPP) to its manufacturing units by benchmarking the same with...

  8. TPA - CIT-(A) was not empowered to restore the issue to the file of the TPO for deciding afresh. He should have called for a remand report from the TPO and should have...

  9. Addition of payments made through credit card - payment was made by Company and recorded by Company in its books of account - when the assessee was consistently claiming...

  10. Classification of services - Mandap Keeper Service or otherwise - letting out of the auditorium - cultural functions are also social functions and renting out the hall...

  11. Tribunal's conclusion that Resale Price Method (RPM) is the most appropriate method upheld. Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) had...

  12. Characterization of receipts - Treatment of interest income from staff loans and advances, interest income from other loans and advances and miscellaneous income -...

  13. Validity of order u/s 92CA (3) on the ground of limitation as contemplated u/s 153 - As the order of the Ld. TPO is barred by limitation, there is no variation to the...

  14. Guest house & garden given on rent for marriage functions - temporary occupation of guest house & garden was being allowed to the customers along with other facilities...

  15. TP adjustment in respect of franchise fee - prudence of expenditure - TPO cannot step into the shoes of assessee to decide prudence of expenditure. The TPO failed to...

 

Quick Updates:Latest Updates