TP Adjustment - writ against DRP order - admission of additional ...

Case Laws Income Tax

May 16, 2019

TP Adjustment - writ against DRP order - admission of additional documents and seek a remand report from the AO can only mean that the panel was of the view that further examination of the issue by the Department was called for - if not satisfied with remand report of TPO, Panel could well have sought a clarification, or directed the officer to carry out further verification - remanded for de novo decision of DRP

View Source

← Previous Next →

TP Adjustment - writ against DRP order - admission of additional ...

Case Laws Income Tax

May 16, 2019

You may also like:

The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP...

TP Adjustment - Addition of international transaction related to the demerger - The High court identified a jurisdictional overreach by the AO, who made an adjustment...

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 Adjustment - working capital adjustment - No document whereby the assessee has made any request before the learned transfer pricing officer or before the learned...

TP adjustment of interest - CIT(A) confirmed upward adjustment towards interest by adopting rupee loan rate instead of LIBOR linked rate in respect of foreign currency...

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

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...

TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...

Impugned order set aside, matter remitted back to Assessing Officer for fresh consideration. Assessing Officer rejected claim based on Tax Audit Report not being duly...

TP adjustment - re-characterization of functionality rejected, agreements relied upon for APA considered. APA applicability and comparables remanded to AO/TPO for fresh...

TP adjustment - Direction in remand proceeding - Customs Duty Adjustment, Air Freight Adjustment and Foreign Exchange Adjustment - If the Tribunal has fixed how such...

TP Adjustment - ALP determination qua domestic transactions entered into by the assessee with its partner u/s 92BA(i) of the Act - no addition on account of TP...

TP Adjustment - secondment of employees by Assessee to its AE - the benchmarking done by the TPO by applying the same rate of thirty party placement agency is not...

TP Adjustment - Receipt of royalty income from its associated enterprises - when the approach adopted by the assessee is found to be acceptable, the adjustment...

The assessing officer (AO) exceeded jurisdiction by reclassifying income as fees for technical services (FTS) instead of royalty, contrary to the limited remand order...

Quick Updates: