TP adjustment in export of finished goods to AE - comparison of ...

Transfer Pricing Case Rejects CUP Method for Export Pricing Due to Geographical Differences Impacting Arm's Length Price Assessment.

July 24, 2019

Case Laws Income Tax AT

TP adjustment in export of finished goods to AE - comparison of the price charged to non–AEs located in India with the price charged to AEs in foreign countries cannot be considered to be a CUP to determine the ALP being situated in different geographical locations, as there may be various factors/reasons which could have influenced the price charged - CUP rejected

View Source

← Previous Next →

TP adjustment in export of finished goods to AE - comparison of ...

Transfer Pricing Case Rejects CUP Method for Export Pricing Due to Geographical Differences Impacting Arm's Length Price Assessment.

July 24, 2019

Case Laws Income Tax AT

You may also like:

The ITAT allowed the revenue's appeal for statistical purposes and remitted the matter back to the Assessing Officer to re-examine the issue and refer it to the Transfer...

The High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) which had approved the Comparable Uncontrolled Price (CUP) method adopted by the assessee for...

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

The High Court held that a change in the approach of assessing tax, without any statutory change, leads to uncertainty in cash flow and fund flow, which are crucial for...

The Tribunal meticulously analyzed each issue, heavily relying on precedent ITAT decisions and the specifics of the case presented. For the major contentious points,...

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...

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

This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

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

Transfer Pricing Adjustments - benchmarking the purchase of SIM cards by the assessee from its AEs - selection of MAM - CUP v/s RPM - CIT(A) has incorrectly applied the...

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

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

TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

ITAT addressed transfer pricing adjustment regarding business support services between associated enterprises. TPO rejected assessee's TNMM method and entity-level...

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

Quick Updates: