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

Inconsistent Characterization by TPO Leads to Remand for Further Examination of Assessee's Distributor and Agent Roles.

December 27, 2015

Case Laws Income Tax AT

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

← Previous Next →

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

Inconsistent Characterization by TPO Leads to Remand for Further Examination of Assessee's Distributor and Agent Roles.

December 27, 2015

Case Laws Income Tax AT

You may also like:

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 - writ against DRP order - admission of additional documents and seek a remand report from the AO can only mean that the panel was of the view that further...

TP adjustment - re-characterization of functionality rejected, agreements relied upon for APA considered. APA applicability and comparables remanded to AO/TPO for fresh...

ITAT adjudicated a transfer pricing dispute involving comparability analysis and interest computation on outstanding receivables. The tribunal rejected certain...

The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) Adjustment where the Transfer Pricing Officer (TPO) determined the Arm's Length Price...

TP adjustment affirmed for excluding Universal Print Systems Limited and BNR Udyog Limited as functionally dissimilar comparables. Vama Industries Ltd. excluded as not...

The ITAT Indore addressed unexplained cash investment for property purchase post search operation. Addition without cross-examination was challenged. The Tribunal...

The ITAT remanded three issues to the AO/TPO for reconsideration. Regarding transfer pricing, the Tribunal held that the TPO misunderstood the assessee's business...

The Income Tax Appellate Tribunal (ITAT) adjudicated on various transfer pricing issues concerning an assessee. Regarding segmentation of business activities, the ITAT...

TDS u/s 194H - the distributor can only be termed as an agent of assessee in which event providing service to ultimate consumer through the medium of distributor cannot...

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...

Cash deposit during demonetization period treated as unexplained cash credit u/s 68 - CIT(A) sustained addition u/s 69A based on lack of supporting evidence for cash...

TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...

Renting of immovable property service - The appellant entered into agreements with the film distributors under which the film distributors granted copyright license in...

ITAT rejected the TPO's approach of aggregating all international transactions for transfer pricing analysis. The Tribunal found that the TPO improperly combined payment...

Quick Updates: