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 May 2021 Year 2021 This

Determining the ALP under transfer pricing provisions - ...

Case Laws     Income Tax

May 8, 2021

Determining the ALP under transfer pricing provisions - Determination of market value of of electricity - When a captive power plant in an industry supplies electricity to its own manufacturing unit, there is no power distribution cost. The savings of cost of power can be determined only when the rate at which the manufacturing unit of the company purchases power in the open market from the power distribution companies is considered. Imaginary costs which are not incurred cannot guide our decision. - AT

View Source

 


 

You may also like:

  1. TPA - ALP determination - Without complying to the statutory provisions, the Transfer Pricing Officer certainly cannot determine the arm's length price on ad-hoc /...

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

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

  4. 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...

  5. Transfer pricing adjustment - determination of ALP - Once the CIT (Appeals) has rejected the entity level profit margin of the assessee for the purpose of bench marking...

  6. Transfer pricing adjustment - determination of ALP - Not only changing the tested party from the assessee to its AE, the CIT (Appeals) has also selected a domestic...

  7. This case deals with the levy of deficit stamp duty and penalty in a court-conducted auction sale. The key points are: In a court-supervised auction sale, the stamp...

  8. TP Adjustment - selection of MAM - Tribunal held that resale price method adopted by the assessee in determining its ALP of international transactions with AE, is not...

  9. Transfer pricing adjustment - Determination of arm's length price for power transferred by assessee's captive power plant to non-eligible manufacturing units, reducing...

  10. Computation of LTCG - Based on a reading of Section 50CA of the Act, it is clear that where the actual sale consideration on transfer of unlisted equity shares is less...

  11. Determination of Arm’s Length Price – In the guise of determination of ALP, the TPO cannot question the business decision of payment and determine that no services were...

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

  13. The ITAT Chennai ruled on deduction u/s 80IA, focusing on determining the market value of power supplied by the assessee to its industrial units. The AO argued for using...

  14. Most appropriate method for determining the ALP of the royalty - Transfer of intangibles - matter remitted back to the AO/TPO for determination of ALP of royalty by...

  15. Royalty receipts were subject to transfer pricing adjustment by TPO on basis of differences in amounts reflected in Form 3CEB of assessee vis-à-vis its group entities,...

 

Quick Updates:Latest Updates