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 July 2019 Year 2019 This

TP adjustment - exclusion and inclusion of comparables - since ...


ITAT Rules on Transfer Pricing Adjustments; Rejects Comparables Due to Filters and Dissimilarity; No Law Question Arises.

July 24, 2019

Case Laws     Income Tax     HC

TP adjustment - exclusion and inclusion of comparables - since in respect of each of the comparables, the ITAT has given detailed reasons why the comparables should be rejected either because of failing the filter or because of functional dissimilarity and also followed earlier decisions concerning assessee - no substantial question of law arises

View Source

 


 

You may also like:

  1. The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

  2. Transfer pricing adjustment concerning comparability selection and attribution of profits between the respondent assessee and foreign Associated Enterprise. TPO rejected...

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

  4. The Income Tax Appellate Tribunal (ITAT) adjudicated on various transfer pricing issues concerning an assessee. Regarding segmentation of business activities, the ITAT...

  5. 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...

  6. Transfer pricing adjustment - Purchase of goods from Associated Enterprises (AE) - Most Appropriate Method (MAM) - Resale Price Method (RPM) considered as MAM for...

  7. Transfer pricing adjustment rejected assessee's comparable companies in TP study analysis. Directed TPO to examine if companies are functionally comparable, apply...

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

  9. TP Adjustment - comparable selection - The ITAT that the turnover filter cannot be applied as a tool for cherry picking the comparables at the later stage after...

  10. TP Adjustment - selection of most appropriate method (MAM) - Resale Price Method or Transactional Net Margin Method - Introduction of Fresh Comparables - Removal of 3%...

  11. Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections...

  12. 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...

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

  14. Transfer pricing adjustment to international transactions - Non-satisfaction of conditions prescribed u/r 10B(4) for using multiple year data. Assessee required to...

  15. The ITAT provided the following rulings: Regarding TP adjustment for comparable selection and treatment of IT support services as ITeS, the issue requires examination by...

 

Quick Updates:Latest Updates