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 May 2012 Year 2012 This

IT - TP - Selection of comparable transactions - the selection ...

Case Laws     Income Tax

May 16, 2012

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 up exactly identical business model. Only an endeavour should be made so that the comparables should match with the assessee as close/near as possible.

View Source

 


 

You may also like:

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

  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. Transfer pricing adjustment to international transactions - Non-satisfaction of conditions prescribed u/r 10B(4) for using multiple year data. Assessee required to...

  4. TP Adjustment - comparable selection - The Tribunal upheld the inclusion of HSIL Limited in the list of comparables, considering its core business activities in...

  5. TP adjustment - Comparable selection - if finances of the three comparables with reference to their respective annual reports, did show that there was a general trend in...

  6. TP Adjustment - comparable selection - before relying upon any judicial precedent for exclusion or inclusion one has to cross the threshold of rule 10 B (2) of IT Rules,...

  7. TP Adjustment - comparable selection - The High Court upheld the ITAT's decision, emphasizing the principle of comparing entities with similar characteristics. It...

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

  9. TP Adjustment - comparable selection - upper turnover filter - The assessee submits that the turnover of the assessee is only Rs. 124 Crores during the relevant previous...

  10. TP Adjustment - comparable selection - where a concern is selected was showing low employee cost to sales ratio, then such concern cannot be selected while benchmarking...

  11. TP adjustment - comparable selection - RTP - the %age of RPT is determined based on the availability of comparables - The more we restrict, chances of loosing reasonable...

  12. TP adjustment - comparable selection - Rule 10B(4)- the data to be used in analysing the comparability of an uncontrolled transaction shall be the data relating to the...

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

  14. 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...

  15. TP adjustment - Design Engineering Services - Selection of comparable - Since the assessee is not providing any Software services and the software services of this...

 

Quick Updates:Latest Updates