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 2018 Year 2018 This

DRP had summarily upheld the change from TNMM to CUP method ...


DRP Criticized for Unjustified Shift from TNMM to CUP Method in Tax Addition Decision Lacking Proper Rationale.

April 2, 2018

Case Laws     Income Tax     AT

DRP had summarily upheld the change from TNMM to CUP method without assigning any cogent reason whatsoever. By no means it is justified to keep on finding a method for addition by trial and error method - there was no justification in rejecting the TNMM method applied by the assessee as in the preceding year - AT

View Source

 


 

You may also like:

  1. The Appellate Tribunal considered TP adjustment on brokerage commission received from related parties. It found TNMM method appropriate for benchmarking the commission...

  2. TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net...

  3. The High Court held that a change in the approach of assessing tax, without any statutory change, leads to uncertainty in cash flow and fund flow, which are crucial for...

  4. TP Adjustment - the TPO is erred in adopting CUP method for few transactions when he has accepted overwhelming majority of transactions under TNMM method. The DRP...

  5. The High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) which had approved the Comparable Uncontrolled Price (CUP) method adopted by the assessee for...

  6. The ITAT allowed the revenue's appeal for statistical purposes and remitted the matter back to the Assessing Officer to re-examine the issue and refer it to the Transfer...

  7. TP Adjustment - International transactions with its AEs for providing software consultancy services - Selection of MAM - DRP without appreciating the above facts, has...

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

  9. This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

  10. TP Adjustment - selection of most appropriate method (MAM) - Resale Price Method or Transactional Net Margin Method - Introduction of Fresh Comparables - Removal of 3%...

  11. TP Adjustment - selection of MAM [Most Appropriate Method] - The High Court upheld the Tribunal's decision, affirming TNMM as the appropriate method for benchmarking...

  12. TP Adjustment - ALP of International Transactions of import of fixed assets - Even though the Ld. TPO had mentioned that he is following CUP method as the most...

  13. TP Adjustment - MAM selection - once TNMM has been accepted under the similar FAR, there is no reason to deviate by adopting CUP Method and other methods admittedly are...

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

  15. TP Adjustment - selection of MAM - RPM or TNMM or Profit Split method [PSM] - Assessee has came out with a contention that if the TNMM is to be applied, then its...

 

Quick Updates:Latest Updates