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 January 2023 Year 2023 This

TP Adjustment - Rejection of Associated Enterprises as the ...


CIT(A) Overrules TPO: Geographical Location Not a Valid Reason to Reject Foreign Associated Enterprises as Tested Party.

January 12, 2023

Case Laws     Income Tax     AT

TP Adjustment - Rejection of Associated Enterprises as the tested party - foreign Associated Enterprises satisfied all the criteria for being taken as a tested party. TPO merely rejected the same as Associated Enterprises is located in different geographical locations. It a proper justification by the learned Transfer Pricing Officer to reject the foreign Associated Enterprises as a tested party. - CIT(A) order diciding the issue in favor of assessee is affirmed. - AT

View Source

 


 

You may also like:

  1. The court quashed the impugned orders rejecting the appeal as the appellate authority failed to assign any reasons, violating principles of natural justice. It is...

  2. Exemption u/s 11 - registration u/sec. 12AA denied - CIT(E) rejected the 12A registration on the ground that clause mentioned in the gift deed is not in accordance with...

  3. 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...

  4. TP Adjustment - TPO arriving ALP by using TNMM Method and rejecting the CPM Method used by the appellant company for the purpose of determining ALP - In any case, the...

  5. TP adjustment in export of finished goods to AE - comparison of the price charged to non–AEs located in India with the price charged to AEs in foreign countries cannot...

  6. The ITAT Mumbai held that the Transfer Pricing Officer (TPO) unjustifiably rejected the benchmarking analysis done by the assessee for determining the Arm's Length Price...

  7. TPA - ALP - CIT(A) held that volume of domestic sale of components/parts was quite insignificant to constitute a valid comparable with the export transactions. For all...

  8. TDS u/s 192 - LTC to an employee - exemption u/s 10(5) - foreign travel - A foreign travel also frustrates the basic purpose of LTC. The basic objective of the LTC...

  9. Validity of order u/s 92CA - time limit for passing of the TPO order - period of limitation - despite the fact that the reference made to the Ld. TPO is valid, in...

  10. CIT(A) deleted addition on unaccounted business income, accepting assessee's retraction of statement recorded u/s 132(4). CIT(A) agreed cash payment of 60 crores by...

  11. This trade circular clarifies the determination of place of supply and export benefits for advertising services provided by Indian advertising agencies to foreign...

  12. This circular clarifies the determination of place of supply and export benefits for advertising services provided by Indian advertising agencies to foreign clients. Key...

  13. ITAT affirmed weighted deduction eligibility u/s 35(2AB) for in-house scientific research expenditure. While R&D expenses incurred within India qualify for weighted...

  14. Writ petition challenging order of assessment and DRC-07 notice issued without opportunity to petitioner, violating principles of natural justice. Held that no reasons...

  15. DRI busted Foreign Currency Smuggling Racket involving Foreign Nationals; Foreign Currencies worth ₹ 6.14 crore seized

 

Quick Updates:Latest Updates