TPA - comparable selection - substantial question of law - the ...

Case Laws Income Tax

October 4, 2018

TPA - comparable selection - substantial question of law - the Revenue has routinely brought such matters before this Court knowing fully well that the Transfer Pricing particularly with regard to exclusion and inclusion of certain comparables to determine Arm's Length Price (ALP) would not necessarily give rise to purely legal questions or substantial questions of law.

View Source

← Previous Next →

TPA - comparable selection - substantial question of law - the ...

Case Laws Income Tax

October 4, 2018

You may also like:

The Tribunal set aside the disallowance of short-term loss claimed by the assessee in the Profit and Loss Account, holding that the shares were acquired under a normal...

The High Court dismissed the appeal filed by the assessing officer against the order of the Income Tax Appellate Tribunal, holding that no substantial question of law...

Jurisdiction of civil court u/s 34 of SARFAESI Act was in question. Suit for declaration and permanent prohibitory injunction was rejected by lower courts under Order...

TPA - comparable selection - companies with revenues less than 75% from software development services would be ideal to be excluded, as economic circumstances of such...

TPA - comparable selection - ALP - substantial question of law or facts - mere dissatisfaction with the findings of facts arrived at by the learned Tribunal is not at...

Substantial question of law to be made out u/s 260A or not? - Undisclosed income surrendered during the Search and Seizure action - to be taxed at normal rate or tax...

Addition u/s 68 - substantial question of law - The Supreme court has held that, the jurisdiction of the High Court to interfere with the orders passed by the Courts...

The case pertains to additions made by the Assessing Officer on account of bogus share application money and commission for bogus accommodation entries. The ITAT deleted...

Substantial question of law to be made u/s 260A - prerequisite of admission of the appeal before the High court - The ITAT hold that the assessee had correctly offered...

TPA - comparable selection - turnover filter application - turnover filter is one of the essential filter in order to select comparables when acted in same atmosphere -...

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

Validity of the decision High Court deciding the appeal on admission state itself on merit - The Supreme Court observed that while the High Court had framed certain...

Seizure of goods as smuggled into the country from Myanmar u/s 130 of the Customs Act, 1962. The burden of proof lies on the respondent u/s 123 to show that the seized...

Selection of comparable - TPA - a company cannot be selected as a comparable not only on the reason of failing employee cost filter, but also due to amalgamation during...

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

Quick Updates: