Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights April 2017 Year 2017 This

TPA - selection of comparables - challenging the approach of ...

Case Laws     Income Tax

April 26, 2017

TPA - selection of comparables - challenging the approach of bifurcating single transaction of marketing and after sales support service into the separate transaction of marketing support service and technical support service - AO/TPO directed to address the issues - AT

View Source

 


 

You may also like:

  1. IT - TP - Selection of comparable transactions - the selection of comparables and selection of similar transactions is not easy to find out and a difficult task to pick...

  2. TPA - comparable selection - turnover filter application - turnover filter is one of the essential filter in order to select comparables when acted in same atmosphere -...

  3. Transfer Pricing Adjustments - Selection of the most appropriate method (MAM) for determining the arm's length price (ALP) - The assessee's choice to adopt the 'other...

  4. Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

  5. TP Adjustment - selection of MAM - CUP cannot be applied on basis of comparable uncontrolled transactions- internal or external- that are undertaken in different...

  6. TPA - One of the comparables Caliber Point Business Solutions has related party transactions of 30% of Revenue and going by the threshold filter of 25% of the related...

  7. Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

  8. TPA - comparable selection - companies with revenues less than 75% from software development services would be ideal to be excluded, as economic circumstances of such...

  9. Comparable selection for determining arm's length price (ALP) adjustment. Appeals limited to including or excluding certain uncontrolled entities as comparables...

  10. TP Adjustment - Comparable selection - determination of the arm’s length price (ALP) of international transactions - The appellant contested the inclusion of two...

  11. TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated...

  12. TP adjustment - comparable selection - functinal dissimilarity - media content and TV broadcasting are totally dissimilar activities - not at all comparable - AO/ TPO to...

  13. Transfer pricing adjustment concerning comparability selection and attribution of profits between the respondent assessee and foreign Associated Enterprise. TPO rejected...

  14. TPA - comparable selection - substantial question of law - the Revenue has routinely brought such matters before this Court knowing fully well that the Transfer Pricing...

  15. TPA - selection of comparable - the companies having diminishing revenue should not be excluded, but, only the companies having persistent losses should be expelled from...

 

Quick Updates:Latest Updates