Transfer pricing adjustment - determination of ALP - merely ...

Case Laws Income Tax

March 29, 2016

Transfer pricing adjustment - determination of ALP - merely because the assessee-company incurred more expenditure on AMP compared to the expenditure incurred by comparable companies, it cannot be inferred that there existed international transaction between assessee-company and its foreign AE - AT

View Source

← Previous Next →

Transfer pricing adjustment - determination of ALP - merely ...

Case Laws Income Tax

March 29, 2016

You may also like:

Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

Transfer pricing adjustment - determination of ALP - Not only changing the tested party from the assessee to its AE, the CIT (Appeals) has also selected a domestic...

Transfer pricing adjustment - determination of ALP - Once the CIT (Appeals) has rejected the entity level profit margin of the assessee for the purpose of bench marking...

TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not...

TPA - This is a case in which transfer pricing provisions cannot be applied because the application of ALP adjustment will indeed result in erosion of Indian tax base-...

Transfer pricing adjustment – Determination of ALP of International License Revenue - Cost of international rights – media rights in respect of BCCI cricket - decided...

Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

TP adjustment - ALP determination - Selection or change in Most Appropriate Method (MAM) - “Other Method" v/s "CUP Method" - Assessee can resile from the most...

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)...

Quick Updates: