TPA - ALP determination - assessee has to submit the segmental ...

Case Laws Income Tax

January 23, 2018

TPA - ALP determination - assessee has to submit the segmental results based on the absorption of overhead on capacity utilization and idle capacity. This is imperative that assessee allocates manufacturing overhead, administrative overhead and other fixed overheads on the basis of capacity utilization. - AT

View Source

← Previous Next →

TPA - ALP determination - assessee has to submit the segmental ...

Case Laws Income Tax

January 23, 2018

You may also like:

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-...

TPA - Determination of ALP - The factum of the assessee having a loss is no ground to reject PSM as the MAM - AT

TPA - Application of the proviso to Section 92C(2) - ALP determination - option available to an assessee in the fixation of the arms length price [ALP for brevity] under...

Transfer pricing adjustment - determination of ALP - Once the CIT (Appeals) has rejected the entity level profit margin of the assessee for the purpose of bench marking...

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

TPA - determination of ALP - TP adjustment by applying Bright Line Test (BLT) is not sustainable on protective basis having no statutory mandate.

TPA - ALP determination - AO/TPO directed to adopt CUP method for the medical transcription services and TNMM for the software development services - AT

TP Adjustment - benefit test - authorities below have fatally erred in applying the benefit test as rightly contended by the Ld. Counsel of the assessee. Furthermore, it...

TPA - Comparability - the segmental results taken by the TPO of this company have been influenced by the mergers and acquisitions taking place during the year, thereby...

Transfer pricing adjustment – determination of ALP by taking segmental results without looking into as to whether the two segments are interlinked or inter-related...

TP adjustment - ALP determination - Selection or change in Most Appropriate Method (MAM) - “Other Method" v/s "CUP Method" - Assessee can resile from the most...

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

TP Adjustment - determination of arm’s length price, ALP - Transactions with the local vendors the terms of which are not influenced by Comer SpA cannot be treated as...

Determination of arm’s length price (ALP) - TPA - working capital adjustment has to be allowed based on the working capital requirements of the assessee and the...

TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

Quick Updates: