TP adjustment - The issue of related party transactions in ...

Customs Data and Related Party Transactions: Challenges in Determining Uncontrolled Transaction Prices Without Full Contract Details.

August 7, 2023

Case Laws Income Tax AT

TP adjustment - The issue of related party transactions in customs data would equally apply to any other public data as well. In the absence of complete details of the differences arising out of contract terms and product quality, the customs data being Govt, notified would provide a reasonable basis for arriving at the uncontrolled transaction price. - AT

View Source

← Previous Next →

TP adjustment - The issue of related party transactions in ...

Customs Data and Related Party Transactions: Challenges in Determining Uncontrolled Transaction Prices Without Full Contract Details.

August 7, 2023

Case Laws Income Tax AT

You may also like:

TP adjustment - comparable selection - Rule 10B(4)- the data to be used in analysing the comparability of an uncontrolled transaction shall be the data relating to the...

Valuation - undervaluation - “Polo” and “Vento” models of their car - related party transaction - interconnected undertakings - Mutuality of Interest - It is found that...

The Appellant, a related party unsecured financial creditor, challenged the resolution plan approved by the Committee of Creditors (CoC) and the Adjudicating Authority,...

TPA - One of the comparables Caliber Point Business Solutions has related party transactions of 30% of Revenue and going by the threshold filter of 25% of the related...

Transfer pricing adjustment to international transactions - Non-satisfaction of conditions prescribed u/r 10B(4) for using multiple year data. Assessee required to...

Transaction value - Valuation (Customs) - Special or abnormal discount to the related buyers which were in excess of 3% discount - The Appellate Tribunal observed that...

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...

Resolution Professional's decision to remove appellant from Committee of Creditors upheld by NCLAT. The appellant, Hari Vitthal Mission, was determined to be a related...

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

The Supreme Court held that the lookback period for related party transactions u/s 43 of the Insolvency and Bankruptcy Code (IBC) is two years before the insolvency...

CIRP - discrimination of Related Party Financial or Operational Creditor - IBC treats related parties as a separate category for specified purposes, excluding from the...

CIRP proceedings - Financial Creditors - Related party - while the default rule under the first proviso to Section 21(2) is that only those financial creditors that are...

The circular clarifies the place of supply for data hosting services provided by Indian service providers to overseas cloud computing service providers. It addresses...

Valuation - related party transaction - The transaction of ₹ 5 lakhs as loan on payment of interest cannot be the reason for holding partnership and private...

Dispute regarding valuation of imported goods under Customs Valuation Rules. Related parties involved, 10% loading applied to transaction value earlier. New Customs...

Quick Updates: