TP Adjustment - international transaction involving payment of ...

Diesel India's Royalty Payment Deemed Arm's Length; Transfer Pricing Evaluation Confirms Compliance with Regulations.

March 7, 2022

Case Laws Income Tax AT

TP Adjustment - international transaction involving payment of royalty undertaken by Diesel India with its Associated Enterprise (“AE”) - the arithmetic mean of comparables comes to 5.25 which is more than the royalty paid by the assessee. The royalty paid by the assessee thus within arm”s length range. - AT

View Source

← Previous Next →

TP Adjustment - international transaction involving payment of ...

Diesel India's Royalty Payment Deemed Arm's Length; Transfer Pricing Evaluation Confirms Compliance with Regulations.

March 7, 2022

Case Laws Income Tax AT

You may also like:

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...

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

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)...

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

Royalty Benchmarking - assessee had adopted TNMM at the entity level in which process royalty payment is considered as closely linked transaction and part of operating...

The ITAT set aside the DRP's order regarding transfer pricing adjustments for royalty payments, directing the matter back to the TPO for further examination to establish...

The Income Tax Appellate Tribunal held that the export commission paid by the assessee to foreign agents in Korea and Indonesia for sales, marketing, and customer...

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

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

TPA - where the variation between the arm’s length price determined u/s 92C and the price at which the international transaction or specified domestic transaction has...

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...

TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's Length Price is required to be determined for a transaction with specified persons in section 40A(2)(b)...

Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

TP adjustment - Determining the arms’ length value for sale of steam at Rs. “nil” - scope of the quotation obtained by the assessee from SSPL - the quotation obtained by...

Quick Updates: