Transfer pricing adjustment - It is not known how the Transfer ...

Transfer Pricing Officer Criticized for Unjustified Disallowance Due to Lack of Comparable Cases and Transparency in Assessment.

June 16, 2016

Case Laws Income Tax AT

Transfer pricing adjustment - It is not known how the Transfer Pricing Officer came to know that the volume and quality of services received by the assessee was disproportionate to its payment - Without identifying the comparable cases, estimation of the disallowance without any base is not called for. - AT

View Source

← Previous Next →

Transfer pricing adjustment - It is not known how the Transfer ...

Transfer Pricing Officer Criticized for Unjustified Disallowance Due to Lack of Comparable Cases and Transparency in Assessment.

June 16, 2016

Case Laws Income Tax AT

You may also like:

The Principal Commissioner or Commissioner having jurisdiction over transfer pricing matters has been empowered, effective April 1, 2022, to invoke revisionary action...

The ITAT held that the Transfer Pricing Officer's order was barred by limitation as it was not passed within 60 days from the date of the final assessment order as...

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

The ITAT allowed the assessee's appeal for statistical purposes and remanded the matter to the Assessing Officer/Transfer Pricing Officer for fresh adjudication....

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)...

Reopening of assessment u/s 147 - it appears that the AO has recorded to the effect that he could not refer the matter to the Transfer Pricing Officer nor could he...

If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

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

Disallowance of commission expenses due to lack of evidence regarding services rendered. Valuation of construction work-in-progress issue dismissed as academic....

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

This is a summary of an Income Tax Appellate Tribunal (ITAT) order dealing with various transfer pricing and deduction issues. The key points are: Transfer pricing...

The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

The Appellate Tribunal addressed three main issues raised by the Assessee against the assessment order. Firstly, regarding the disallowance of job work charges to a...

The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

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...

Quick Updates: