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 January 2021 Year 2021 This

TP Adjustment - applicability of Section 144C(13) - As provided ...

Case Laws     Income Tax

January 6, 2021

TP Adjustment - applicability of Section 144C(13) - As provided in the Section 144C(13) of the Act, the final order of the Assessing Officer should be in conformity with the directions given by the DRP. In the present case, while working out the ALP adjustment, he has not followed the direction of the DRP, consequently, the assessment order is bad in law - AT

View Source

 


 

You may also like:

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

  2. 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...

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

  4. 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)...

  5. TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

  6. TP adjustment - specified domestic transactions (SDT) - The ITAT held that since the provision (Section 92BA(i)) was omitted without a saving clause effective from...

  7. 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...

  8. TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result...

  9. TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of...

  10. TP Adjustment - AMP expenses by applying bright line test on protective basis - TP adjustment amounting by applying BLT is not sustainable on protective basis having no...

  11. TP Adjustment - CIT(A) under the garb of "rule of consistency" adopted the TP analysis made by the TPO - This method of TP analysis is unheard of as every assessment...

  12. The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should...

  13. Rectification of mistake u/s 154 - TP Adjustment - arm's length price adjustment - even after holding that there was no apparent mistake in the DRP directions, whereas a...

  14. TP adjustment - AO/TPO has not followed direction of DRP - As per section 144C(13) the AO is bound to pass the final assessment order in conformity with the direction of...

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

 

Quick Updates:Latest Updates