Transfer pricing adjustment - The mandate of the CBDT circular ...

Case Laws Income Tax

September 1, 2018

Transfer pricing adjustment - The mandate of the CBDT circular is that the Assessing Officer should make a reference to the Transfer Pricing Officer - There is no acceptable or justifiable reason on record for refusing to abide by this condition in the CBDT circular.

View Source

← Previous Next →

Transfer pricing adjustment - The mandate of the CBDT circular ...

Case Laws Income Tax

September 1, 2018

You may also like:

Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

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) -...

TP Adjustments - AO does not have the jurisdiction to propose any transfer pricing adjustment in case where he has not made any reference to the TPO. Therefore the...

The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

Reopening of assessment u/s 147 - TP Adjustment - The impugned order is not a suo-motu proceedings initiated by the Transfer Pricing Officer under Sub-Section 2B of...

Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

TP - Arm's length price - CBDT instruction does not restrict the powers of the AO from making references to the Transfer Pricing Officer after 30th June 2003

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

Regarding the scope of Section 92BA(i) as omitted, the Tribunal held that the reference made to the Transfer Pricing Officer (TPO) for the specified domestic transaction...

TP Adjustment - Reference to TPO - none of the two conditions enshrined in the Instruction of 2016 were satisfied in as much as neither transfer pricing adjustment of...

The Principal Commissioner or Commissioner having jurisdiction over transfer pricing matters has been empowered, effective April 1, 2022, to invoke revisionary action...

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 Adjustment - Adjustment on account of notional interest on the receivables - when the assessee is having their own funds and not paying interest on any...

The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

Quick Updates: