TP Adjustment - the TPO is erred in adopting CUP method for few ...

December 14, 2022

Case Laws Income Tax AT

TP Adjustment - the TPO is erred in adopting CUP method for few transactions when he has accepted overwhelming majority of transactions under TNMM method. The DRP without appreciating the above facts, simply sustained TP adjustment suggested by the TPO. Hence, we direct the AO/TPO to delete TP adjustment made towards few transactions by adopting CUP as most appropriate method. - AT

View Source

← Previous Next →

TP Adjustment - the TPO is erred in adopting CUP method for few ...

December 14, 2022

Case Laws Income Tax AT

You may also like:

TP Adjustment - ALP of International Transactions of import of fixed assets - Even though the Ld. TPO had mentioned that he is following CUP method as the most...

Transfer pricing adjustment - Majority of transactions have been accepted to be at arm's length price by the TPO by applying TNMM method, only in respect of few...

TP Adjustment - International transactions with its AEs for providing software consultancy services - Selection of MAM - DRP without appreciating the above facts, has...

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 - US Transactions non US Transactions - scope of MAP agreement - It would be better to refer to the settlement arrived between the competent authority of...

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...

TP adjustment on account of back-to-back counter bank guarantee - TPO, by considering the rate charged by Bank of Baroda for issuance of guarantee against 100% counter...

TP adjustment - Intragroup services filed by the assessee from its AE - Either way when the Revenue seeks to disturb the Most Appropriate Method adopted by the assessee,...

TP adjustment - ALP determination - Selection or change in Most Appropriate Method (MAM) - “Other Method" v/s "CUP Method" - Assessee can resile from the most...

The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should...

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

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...

The High Court held that a change in the approach of assessing tax, without any statutory change, leads to uncertainty in cash flow and fund flow, which are crucial for...

Transfer pricing (TP) adjustments - The method adopted by the TPO suffered from the defect of the comparing uncomparable chemicals, using an average variation between...

Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for...

Quick Updates: