Transfer pricing - selection of comparable - Every difference ...

Case Laws Income Tax

July 24, 2018

Transfer pricing - selection of comparable - Every difference which is likely to affect the comparability analysis has to be taken note of and suitable adjustment has to be made to bring the comparables on par with the assessee for comparing of their operating margin

View Source

← Previous Next →

Transfer pricing - selection of comparable - Every difference ...

Case Laws Income Tax

July 24, 2018

You may also like:

Transfer Pricing adjustments - Arms length price (ALP) - u/s 92CA - software development and IT enabled services - selection of comparable - Size matters in business

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

Transfer pricing - selection of comparable - Capacity adjustment to account for differences in capacity utilization of the Appellant vis-à-vis the comparable -...

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...

Transfer pricing adjustment - selection of comparable - Tribunal specified the aspects that may be kept in mind by the DRP while addressing the objections in respect to...

Transfer pricing adjustment - selection of comparable - AO/TPO is directed to work out the ALP of the assessee with direction - AT

Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

Transfer pricing - arm's length price - Selection of comparable - Other enterprises have claimed depreciation at much lower amounts. Size of the assets besides the age...

Transfer pricing adjustment – Computation of ALP – Advances made to overseas subsidiaries – The differences are so fundamental that these differences, to use the...

Transfer pricing adjustment - primary responsibility to bench mark the transactions with comparable cases - the certificate issued by the auditors only spell out the...

Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

Transfer Pricing – Arm Length Price – selection of comparables - assessee is not estopped from pointing out a mistake in the assessment. - AT

Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

Royalty receipts were subject to transfer pricing adjustment by TPO on basis of differences in amounts reflected in Form 3CEB of assessee vis-Ã -vis its group entities,...

TP Adjustment - Selection of comparable - An inclusion of certain entity in the list of comparables by the assessee in transfer pricing study report cannot act as...

Quick Updates: