TPA - Arms length price (ALP) - AO has mentioned that the ...

Case Laws Income Tax

July 9, 2016

TPA - Arms length price (ALP) - AO has mentioned that the payment made to the AE was excess and unreasonable. But, not a single word has been uttered in the order as to how it was excess or not reasonable. Any disallowance or addition, whether under chapter IV or chapter X of the Act, cannot be made on ad hoc basis - AT

View Source

← Previous Next →

TPA - Arms length price (ALP) - AO has mentioned that the ...

Case Laws Income Tax

July 9, 2016

You may also like:

TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's Length Price is required to be determined for a transaction with specified persons in section 40A(2)(b)...

TPA - ALP determination - Without complying to the statutory provisions, the Transfer Pricing Officer certainly cannot determine the arm's length price on ad-hoc /...

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)...

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

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...

Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

TPA - where the variation between the arm’s length price determined u/s 92C and the price at which the international transaction or specified domestic transaction has...

Arm Length Price (ALP) - Interest free loans to the sister concern by the Assessee-company - AE's who are 100% subsidiaries - The appropriate rate would be LIBOR plus 2% - AT

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-...

Arm Length Price adjustment – The very foundation of addition in arm's length price on account of excess credit period is devoid of any legally sustainable merits or...

TP Adjustment - where the Tribunal has accepted the international transaction to be at Arm’s Length Price in the hands of AE, then the international transaction that the...

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 - arm’s length price of interest on short term loan granted to the AE - The fact that the assessee has provided a short term loan only for a period of 15...

Penalty u/s 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it...

Transfer pricing adjustment - determining ALP - Assessing Officer was thus in error not only in resorting to an unscientific and unrecognized method ascertaining the...

Quick Updates: