TP Adjustment - international transaction pertaining to purchase ...

Dispute on 8% Markup in Transfer Pricing for Capital Goods Purchase Remanded to DRP for Arm's Length Price Assessment.

August 23, 2021

Case Laws Income Tax AT

TP Adjustment - international transaction pertaining to purchase of capital goods from AE - the issue of allowability or not of the markup of 8% charged by the AE has not been determined as per the approved methods, we hereby deem it fit to remand the matter to the file of the ld. DRP to determine the ALP as per the approved methods after giving an opportunity to the assessee to make their submissions. - AT

View Source

← Previous Next →

TP Adjustment - international transaction pertaining to purchase ...

Dispute on 8% Markup in Transfer Pricing for Capital Goods Purchase Remanded to DRP for Arm's Length Price Assessment.

August 23, 2021

Case Laws Income Tax AT

You may also like:

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)...

Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

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

If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

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

TP Adjustment - Equipment would not have been imported at NIL price even in an independent scenario. Moreover, we do not find that the TPO has applied any method to...

Levy of GST - Valuation - determination of margin - old and used motor vehicles - claim of deduction of cost incurred on refurbishment from the margin - It is noticed...

The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment...

CENVAT Credit - transfer of unutilized credit, on shifting of factory - Transfer of unutilized credit also denied on the ground that appellants have shifted on inputs...

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...

The transfer of title of goods by the Applicant to its customers or multiple transfers within the Free Trade Warehousing Zone (FTWZ) gets covered under para 8(a) of...

The ITAT held that the Dispute Resolution Panel (DRP) lacks jurisdiction to direct the Transfer Pricing Officer or Assessing Officer in second-round proceedings after...

The ITAT held that the Transfer Pricing Officer (TPO) should consider comparables dealing in electronic products only, supported by a technical expert's certificate,...

The provisions govern taxation of capital assets or stock-in-trade transfers during entity dissolution or reconstitution. Under both Sec 9B of IT Act 1961 and Cl 8 of IT...

Quick Updates: