Transfer pricing - the TPO proceeded on a false premise that the ...

Case Laws Income Tax

October 22, 2018

Transfer pricing - the TPO proceeded on a false premise that the appellant has not allocated any expenses to the homebase segment, whereas, as demonstrated elsewhere, not only the appellant has allocated routine expenses, the details were also furnished before the lower authorities. - No additions.

View Source

← Previous Next →

Transfer pricing - the TPO proceeded on a false premise that the ...

Case Laws Income Tax

October 22, 2018

You may also like:

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)...

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

Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

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

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 adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment...

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

TP adjustment - Segment results cannot be said to be unreliable. However on perusal of the transfer pricing order, we agree with the ld. DR that these segmented results...

Transfer pricing (TP) adjustment - the learned TPO was not justified in comparing the gross margin in export segment vis-a-vis gross margins in domestic segment. - There...

Transfer pricing issues: Royalty arrangement including trademark, know-how upheld based on CUP method over TNMM. Advertisement expenses remanded for fresh determination....

The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should...

Validity of order passed u/s 92CA - Transfer Pricing - Since the ld. TPO order has been passed on 30/10/2015 which is clearly barred by limitation by one day by virtue...

TP adjustment - Jurisdiction of TPO - TPO suo motu examined the domestic transaction and made transfer pricing adjustment - in relation to a specified domestic...

TP adjustments towards AMP expenditure pertaining to trading segment AND reimbursement of warranty expenses to AE - the AMP expenses and warranty expenses cannot be...

Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

Quick Updates: