TP adjustment - DRP gave clear directions to the TPO to ...

DRP Directs TPO to Reassess Comparable Entities in Transfer Pricing Case; AO Cannot Amend Final Order.

November 4, 2022

Case Laws Income Tax AT

TP adjustment - DRP gave clear directions to the TPO to re-examine the inclusion of comparable - the jurisdictional AO has become functus officio once the final assessment order is passed and that there is no authority for him to pass any order modifying the final assessment order. - AT

View Source

← Previous Next →

TP adjustment - DRP gave clear directions to the TPO to ...

DRP Directs TPO to Reassess Comparable Entities in Transfer Pricing Case; AO Cannot Amend Final Order.

November 4, 2022

Case Laws Income Tax AT

You may also like:

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

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)...

The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) Adjustment where the Transfer Pricing Officer (TPO) determined the Arm's Length Price...

TP adjustment in Distribution activity, described as ESAS - ALP and the consequential transfer pricing adjustment are contemplated only in respect of the international...

Comparable selection - Tribunal remanded issue of inclusion of companies to TPO to examine functional comparability after applying applicable filters. If functionally...

Transfer pricing adjustment - selection of comparable - AO/TPO is directed to work out the ALP of the assessee with direction - AT

The Tribunal held that the Transfer Pricing Officer (TPO)/Assessing Officer (AO) should exclude companies having turnover exceeding Rs. 200 crores from the comparability...

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

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

ITAT excluded four entities (Eclerx Services Ltd., TCS E-serve Ltd., Infosys BPO Ltd., and Tech. Mahindra Ltd.) from the comparable array in transfer pricing adjustment....

Transfer pricing adjustment rejected assessee's comparable companies in TP study analysis. Directed TPO to examine if companies are functionally comparable, apply...

The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

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)...

Tribunal's conclusion that Resale Price Method (RPM) is the most appropriate method upheld. Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) had...

Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude...

Quick Updates: