Transfer pricing adjustment - Nature of amendment - prospective ...

Case Laws Income Tax

May 16, 2016

Transfer pricing adjustment - Nature of amendment - prospective or retrospective - It does not make sense that someone tells you today as to how you should have behaved yesterday, and then goes on to levy a tax because you did not behave in that manner yesterday. - AT

View Source

← Previous Next →

Transfer pricing adjustment - Nature of amendment - prospective ...

Case Laws Income Tax

May 16, 2016

You may also like:

Cenvat Credit - Supply to SEZ - Amendment to rule 6 - whether retrospective or prospective - the amendment is clarificatory in nature - held as retrospective - HC

Refund of education cess - export - rebate of duty - amendment is prospective or retrospective – held that amendment is retrospective in nature - refund of education...

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

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) -...

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

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

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...

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...

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

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...

Disallowance u/s 14A r.w.r. 8D - scope of amendment made by the Finance Act, 2022 to Section 14A - Amendment is retrospective or prospective in nature - the amendment 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 - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned...

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)...

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

Quick Updates: