Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights July 2022 Year 2022 This

TP Adjustment - As per the provisions of aforesaid Rule, the ...


Incorrect Valuation in Transfer Pricing: Authorities Failed to Use Comparable Uncontrolled Transactions for IT Support Services.

July 29, 2022

Case Laws     Income Tax     AT

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 charged or paid for the same or similar uncontrolled transaction between non-associated enterprises. However, in the present case, the lower authorities without searching for similar uncontrolled transaction between non-associated enterprises, straightaway treated the value of the international transaction to be at NIL. - TPO as well as learned DRP were not justified in treating the value of international transaction of ‘Payment of Corporate IT Support Services’ to be NIL - AT

View Source

 


 

You may also like:

  1. Transfer Pricing Adjustments - Selection of the most appropriate method (MAM) for determining the arm's length price (ALP) - The assessee's choice to adopt the 'other...

  2. Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections...

  3. 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...

  4. The High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) which had approved the Comparable Uncontrolled Price (CUP) method adopted by the assessee for...

  5. The Tribunal meticulously analyzed each issue, heavily relying on precedent ITAT decisions and the specifics of the case presented. For the major contentious points,...

  6. Deduction u/s 80IA in respect of profits of captive power plants ('CPPs') - The tribunal, referring to the Comparable Uncontrolled Price (CUP) method and previous...

  7. 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)...

  8. This case deals with transfer pricing adjustments made by the tax authorities regarding international transactions involving sale of Paclitaxel, Disodium Pamidronate,...

  9. 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...

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

  11. TP Adjustment - MAM - Considering brokerage rate of all Non-AEs for the comparability purposes - Arm's Length Price (ALP) of broking commissions - The Tribunal directed...

  12. Transfer pricing adjustment - determining ALP - whether hypothetical price which would have been charged under comparable uncontrolled conditions can be taken into...

  13. 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...

  14. The ITAT provided the following rulings: Regarding TP adjustment for comparable selection and treatment of IT support services as ITeS, the issue requires examination by...

  15. Transfer pricing adjustment deleted - the comparables adopted by the assessee are uncontrolled parties and can be considered for the purpose of determining the Arms'...

 

Quick Updates:Latest Updates