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1. 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) -...

2. TP adjustment - tested party - As per Guidance Note on report u/s 92E and transfer pricing guidelines issued by the OECD and united nation practical manual of transfer...

3. Transfer Pricing Adjustment - Transfer Pricing Regulations do not contemplate taking into account future data for the purpose of bench marking - AT

4. Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

5. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

6. 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...

7. Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

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

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

10. TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...

11. CENVAT Credit - transfer of unutilized credit, on shifting of factory - Transfer of unutilized credit also denied on the ground that appellants have shifted on inputs...

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

13. TP Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned...

14. 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)...

15. Jurisdiction of Transfer Pricing Officer - Suo motu, TPO cannot take cognizance of any international transaction for suggesting adjustment in the arm’ s length price,...