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 September 2017 Year 2017 This

When direct CUP between the AE and Tata Communications from whom ...

Case Laws     Income Tax

September 6, 2017

When direct CUP between the AE and Tata Communications from whom the assessee has taken the network on lease is available then the ALP has to be computed under CUP - However, when the assessee has expressed its helplessness to compute the margins separately in respect of the international transactions then the direct CUP available in case of the assessee would be an appropriate method of determination of ALP.

View Source

 


 

You may also like:

  1. Claim of Interest u/s.36(1)(iii) - security deposits paid to director’s wife for taking her bungalow on lease - The said property had been taken on lease by the assessee...

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

  3. TPA - Adjustment of interest for delayed realization of sale from AE - when the assessee is not charging any interest from non AE then there is no case made out by the...

  4. TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

  5. Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for...

  6. Nature of expenses - Taking computers and vehicles taken on lease - deduction of payment of principal amount as revenue expenditure - financial lease or operational...

  7. Principles of Natural Justice - mode of service / communication of orders - As per Section 169(c) and (d) of the GST Act the service of any communication to the e-mail...

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

  9. TP Adjustment - IEX rates for the purpose of benchmarking the transaction of sale of power - if the prices are so divergent and the difference between the two external...

  10. The assessee, a foreign company, earned network transportation fees from its Indian associated enterprise (AE), Damco India Private Limited (DIPL). The Assessing Officer...

  11. Addition on account of lump-sum lease charges received - lease transaction does not give an absolute ownership or title as it can be cancelled and re-entered - assessee...

  12. TP adjustment - royalty paid by the assessee to its AE - selection of MAM - The method of the assessee can be pigeonholed in the “other method” provided in Rule 10AB r.w....

  13. Area based exemption - Refund - Assessee did not take the available Cenvat credit during the period it was available and paid the excess from the PLA and took the refund...

  14. Transfer pricing - determination of ALP - selection of MAM - application of CUP method as against TNMM - AO/TPO directed first apply CUP using some comparable instances...

  15. Classification of imported goods - LAN Network is essentially a system of inter-communication of computers in a given office. They are commonly understood as a computer...

 

Quick Updates:Latest Updates