TP Adjustment - Selection of MAM - transactional net margin ...

TPO Must Use TNMM for Transfer Pricing Adjustments, Comparing Taxpayer Margins with Selected Comparable Companies' Margins.

June 4, 2020

Case Laws Income Tax AT

TP Adjustment - Selection of MAM - transactional net margin method is the most appropriate method, the TPO is directed to examine the international transactions entered into by the assessee applying that method and compare the margin of the assessee with the comparable companies selected by the assessee.

View Source

← Previous Next →

TP Adjustment - Selection of MAM - transactional net margin ...

TPO Must Use TNMM for Transfer Pricing Adjustments, Comparing Taxpayer Margins with Selected Comparable Companies' Margins.

June 4, 2020

Case Laws Income Tax AT

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...

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

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

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...

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...

The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

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

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...

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 (TP) adjustment - the learned TPO was not justified in comparing the gross margin in export segment vis-a-vis gross margins in domestic segment. - There...

Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

ITAT upheld the segmentation of the taxpayer's business into Manufacturing and Trading segments for transfer pricing benchmarking purposes, following the coordinate...

The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

Transfer Pricing Adjustments - downward adjustment made by the TPO and enhanced by the CIT(A) - adoption of the Transactional Net Margin Method (TNMM) over other methods...

Transfer pricing Adjustments - ALP - Once internal comparable was available, along with the segmental details, TPO was required to examine the same and carry out the...

Quick Updates: