TP Adjustment - payment of royalty - comparison in order to ...

Transfer Pricing: Royalty Payments Must Compare Controlled and Uncontrolled Transactions for Accurate Arm's Length Price Assessment.

September 15, 2021

Case Laws Income Tax AT

TP Adjustment - payment of royalty - comparison in order to determine if the ALP cannot be done by comparing the prices charged to by A.E. which is controlled transaction, as the provisions of I.T. Act, mandates that the determination of ALP has to be done by comparison between controlled and un-controlled transactions. - AT

View Source

← Previous Next →

TP Adjustment - payment of royalty - comparison in order to ...

Transfer Pricing: Royalty Payments Must Compare Controlled and Uncontrolled Transactions for Accurate Arm's Length Price Assessment.

September 15, 2021

Case Laws Income Tax AT

You may also like:

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

TP Adjustment - ALP of the royalty paid AE - royalty paid by other group entities are controlled transactions whereas, rule 10B(1)(a) mandates that the price charged for...

Transfer pricing adjustment - adjustment in respect of international transaction relating to export of manufactured IC engines by considering the difference in the gross...

The ITAT Ahmedabad addressed Transfer Pricing (TP) adjustments, focusing on royalty, management fees, and IT allocation costs. The tribunal upheld the use of the...

Transaction between foreign enterprise and its Indian Permanent Establishment (PE) falls within transfer pricing provisions u/s 92B. ITAT held PE must be treated as...

HC held that Comparable Uncontrolled Price (CUP) method was appropriate for determining Arm's Length Price (ALP) for power transfer between eligible and non-eligible...

Transfer pricing adjustments - ALP - The arm's length price can be determined only by making comparison with a comparable uncontrolled transaction and not a comparable...

Valuation of imports from related suppliers and the inclusion or exclusion of royalty in the transaction value. The key points are: Rule 10(1)(c) of the Customs...

Transfer pricing adjustment - arm‘s length pricing of international transactions - Advertising / Marketing and Promotion Expenses - international transaction - Domestic...

TP Adjustment - As per the provisions of aforesaid Rule, the ‘other method’ shall be the method which takes into account the price which has been or would have been...

Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

TP Adjustment - selection of MAM - CUP cannot be applied on basis of comparable uncontrolled transactions- internal or external- that are undertaken in different...

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

Applicability of Transfer pricing provisions - Transactions with joint venture - transactions between the assessee and IJMII do not fall under section 92B(2) -...

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...

Quick Updates: