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

Debate on Transfer Pricing Adjustments: Should Tax Amendments Apply Prospectively or Retrospectively? Retrospective Penalties Criticized.

May 16, 2016

Case Laws Income Tax AT

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

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

Debate on Transfer Pricing Adjustments: Should Tax Amendments Apply Prospectively or Retrospectively? Retrospective Penalties Criticized.

May 16, 2016

Case Laws Income Tax AT

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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...

The High Court held that the amendment introducing the words "or assessable" in Section 50C of the Income Tax Act, effective from October 1, 2009, cannot be applied...

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-...

ITAT determined that NFAC improperly exercised jurisdiction in transfer pricing appeal cases. The tribunal found that CIT(A) at NFAC erroneously assumed jurisdiction...

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