TP Adjustment - ALP adjustment on account of profit mark-up - It ...

Case Laws Income Tax

May 3, 2023

TP Adjustment - ALP adjustment on account of profit mark-up - It cannot be expected that the parent organization supply support services without charging anything for such services rendered. Hence, we hold that the markup of 5% is sufficient to recoup the expenditure involved by the AE in exploration, inspection, testing and finalization of the suitable software. - AT

View Source

← Previous Next →

TP Adjustment - ALP adjustment on account of profit mark-up - It ...

Case Laws Income Tax

May 3, 2023

You may also like:

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...

ALP of the international transaction of payment of Fees for Management services - 5% mark-up under Cost plus method - Even if, we proceed with the assumption that the...

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 - ALP adjustment on account of receipt of commission for Marketing Services - main contention of the appellant is that the functions undertaken by the...

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

TP Adjustment - non granting of adjustment on import duty - as necessary consumption of the material is only booked in the profit and loss account for which the...

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

This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

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 - 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...

Transfer pricing adjustment - determination of ALP - Once the CIT (Appeals) has rejected the entity level profit margin of the assessee for the purpose of bench marking...

The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP...

TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result...

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...

Quick Updates: