TP Adjustment - comparable selection - None of the comparables ...

Case Laws Income Tax

May 20, 2020

TP Adjustment - comparable selection - None of the comparables have been excluded on the ground of high turnover alone. The test of functional similarity applied by the Tribunal is in consonance with the legal position discussed hereinabove. No merit in the contentions urged by the Revenue on this ground. Equally meritless is the contention of the Revenue regarding the bar to challenge the comparables after the acceptance of the filters. The filters are applied to narrow down the search to find the comparables that are closest to the assessee. The use of filters has to be necessarily validated from the annual reports.

View Source

← Previous Next →

TP Adjustment - comparable selection - None of the comparables ...

Case Laws Income Tax

May 20, 2020

You may also like:

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

TP adjustment - comparable selection - functinal dissimilarity - media content and TV broadcasting are totally dissimilar activities - not at all comparable - AO/ TPO to...

TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated...

Comparable selection for determining arm's length price (ALP) adjustment. Appeals limited to including or excluding certain uncontrolled entities as comparables...

TP adjustment - Design Engineering Services - Selection of comparable - Since the assessee is not providing any Software services and the software services of this...

TP adjustment - Comparable selection - if finances of the three comparables with reference to their respective annual reports, did show that there was a general trend in...

TP Adjustment - comparable selection - before relying upon any judicial precedent for exclusion or inclusion one has to cross the threshold of rule 10 B (2) of IT Rules,...

Arm's Length Price adjustment on international transaction – selection of comparable - if abnormal loss making companies are excluded abnormal profit making companies...

TP adjustment - comparable selection - RTP - the %age of RPT is determined based on the availability of comparables - The more we restrict, chances of loosing reasonable...

TP Adjustment - comparable selection - upper turnover filter - The assessee submits that the turnover of the assessee is only Rs. 124 Crores during the relevant previous...

TP Adjustment - comparable selection - where a concern is selected was showing low employee cost to sales ratio, then such concern cannot be selected while benchmarking...

TP adjsutment - “AE” investment banking activities - comparable selection - The persistence loss- making company are normally excluded as comparable. As per the...

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...

TP Adjustment - amount disallowed by the AO, viz., Product development expenses, provision for customer claims should be excluded from the cost while computing margin of...

TP Adjustment - Selection of comparable - An inclusion of certain entity in the list of comparables by the assessee in transfer pricing study report cannot act as...

Quick Updates: