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1. Transfer pricing adjustment - when a quasi Judicial Authority like the DRP deals with lis u/s 144C then it is obligatory on its part to ascribe cogent and germane...

2. Transfer pricing - Order of Dispute Resolution Panel (DRP) - Non-speaking order - when a quasi judicial authority deals with a lis, it is obligatory on its part to...

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

4. Disciplinary proceedings against formerly Appellate Deputy Commissioner - If the order passed by the quasi judicial authority is taken as a foundation for bringing the...

5. The High Court held that the impugned Press Release by the Ministry of Finance, purporting to direct judicial and quasi-judicial authorities to classify all...

6. TP Adjustment - Reference to TPO - none of the two conditions enshrined in the Instruction of 2016 were satisfied in as much as neither transfer pricing adjustment of...

7. Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

8. 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)...

9. TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...

10. TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

11. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

12. Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

13. Transfer pricing - Application of Section 144C - eligible assessee - Appellant contended that as the TPO has not prescribed any adjustment in the Transfer Pricing order....

14. Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

15. Final assessment order passed u/s 143(3) read with Section 144C(13) subsequent to Dispute Resolution Panel (DRP)/Transfer Pricing Officer (TPO) directions deemed invalid...