TP Adjustment - ALP adjustment on account of receipt of ...

Case Laws Income Tax

June 30, 2022

TP Adjustment - ALP adjustment on account of receipt of commission for Marketing Services - main contention of the appellant is that the functions undertaken by the assessee for selling the product is significantly different from what is undertaken for the purpose of earning the commission income from A.E - CIT-A deleted the adjustments - The reasoning given by the TPO that these two segments of the cost does not contribute to profit does not stand to any reason, in as much as the depreciation and the material actually contributes to the profits in the manufacturing segment. - AT

View Source

← Previous Next →

TP Adjustment - ALP adjustment on account of receipt of ...

Case Laws Income Tax

June 30, 2022

You may also like:

TP Adjustment - ALP adjustment qua receipt of management services - the assessee has already filed its detailed paper book in the nature of supportive evidence...

TP Adjustment - ALP determination - intra-group services - TPO cannot stand in judgment on what benefits the assessee has derived from the services and assessee's...

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

TP Adjustment - receipt of management services from AEs - It is difficult to prove the services in terms of numbers but it can be seen only in ease of doing business in...

TP Adjustment - ALP determination qua domestic transactions entered into by the assessee with its partner u/s 92BA(i) of the Act - no addition on account of TP...

TP Adjustment - CIT(A) under the garb of "rule of consistency" adopted the TP analysis made by the TPO - This method of TP analysis is unheard of as every assessment...

TP adjustment on account of payment of overseas support fee - The assessee has its head office outside India and the decision, on the basis of which the assessee gets...

The sub-broker who received commission from the main broker while main broker has paid the service tax on commission received by him cannot be once again subjected to...

TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the...

Recovery of short paid service tax - Construction of Complex Service - adjustment of the excess service tax paid - Service Tax when introduced followed the receipt based...

TP Adjustment - adjustment of brokerage income - assessee also filed submission before the TPO providing detailed explanation with regard to the differences in services...

TP adjustment - ALP of management service fees at Nil - receipt of service from other group companies not doubted - The authorities below cannot sit in judgment over the...

Transfer pricing adjustments - Location Savings and Imputation of mark-up on pass through costs - this intra-group services rendered by the assessee to the parent...

TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of...

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...

Quick Updates: