TP Adjustment - specified domestic transaction of project ...

Case Laws Income Tax

June 2, 2023

TP Adjustment - specified domestic transaction of project management and supervision - Capitalized expenditure - AO is incorrect in determining the arm’s-length price of specified domestic transaction after omission of clause (i) of Section 92BA - the action of the learned transfer-pricing officer in determining the arm’s-length price of project management and supervision fees at Rs Nil and consequent disallowance of depreciation there on is not correct. - AT

View Source

← Previous Next →

TP Adjustment - specified domestic transaction of project ...

Case Laws Income Tax

June 2, 2023

You may also like:

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

The ITAT Delhi held that u/s 92BA, TP adjustment for Specified Domestic Transactions is not applicable post omission of Clause (i) w.e.f. 1.4.2017. Citing Texport...

TP adjustment - Jurisdiction of TPO - TPO suo motu examined the domestic transaction and made transfer pricing adjustment - in relation to a specified domestic...

TP adjustment - specified domestic transactions (SDT) - The ITAT held that since the provision (Section 92BA(i)) was omitted without a saving clause effective from...

TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the...

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...

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...

For the purpose of transfer pricing adjustment, the transaction of the assessee with Associated Enterprise outside the country alone has to be taken into consideration....

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 - regional management services received by the assessee - incorrect factual observations and invalid of assumption of jurisdiction by the TPO who without...

TP adjustment of Technical Assistance fees and project management services not claimed as expenditure but capitalized as project - capital transactions are outside 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 - US Transactions non US Transactions - scope of MAP agreement - It would be better to refer to the settlement arrived between the competent authority of...

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

Quick Updates: