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 February 2019 Year 2019 This

Transfer pricing adjustment - most appropriate method - CUP ...

Case Laws     Income Tax

February 14, 2019

Transfer pricing adjustment - most appropriate method - CUP method was not correct method - AO directed to apply TNMM method to benchmark the international transactions of assessee and compare the margins shown by assessee with the mean margins of comparables which are functionally comparable.

View Source

 


 

You may also like:

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

  2. TP adjustment - application of the Resale Price Method (RPM) as the Most Appropriate Method (‘MAM’) - trading activity - The decision of Supreme Court in Kedarnath Jute...

  3. Transfer pricing adjustment - CUP method as the Most Appropriate Method for determination of ALP for international transactions. The assessee is also directed to...

  4. Transfer pricing adjustment - applicability of CUP to a single combined international transaction of Import of Crystal goods and Crystal components, cannot be considered...

  5. 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...

  6. TP Adjustment - adjustment of brokerage income - assessee also filed submission before the TPO providing detailed explanation with regard to the differences in services...

  7. Transfer pricing (TP) adjustments - The method adopted by the TPO suffered from the defect of the comparing uncomparable chemicals, using an average variation between...

  8. 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...

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

  10. Transfer pricing adjustment deleted - the comparables adopted by the assessee are uncontrolled parties and can be considered for the purpose of determining the Arms'...

  11. TP adjustment on account of back-to-back counter bank guarantee - TPO, by considering the rate charged by Bank of Baroda for issuance of guarantee against 100% counter...

  12. Transfer pricing adjustment - the unusual features which remained unexplained by the assessee, influenced the TPO and the AO to resort to transfer pricing adjustment and...

  13. Transfer Pricing Adjustment - TPO's reliance on loan data from the US and Europe for benchmarking is inappropriate given Bahrain's distinct economic environment and...

  14. Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

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

 

Quick Updates:Latest Updates