TP Adjustment - comparable selection - Clearly, since according ...

High Court Affirms Tribunal's Exclusion of Comparables for Transfer Pricing Due to Lack of Segmental Data Consistency.

September 26, 2023

Case Laws Income Tax HC

TP Adjustment - comparable selection - Clearly, since according to the Tribunal the segmental information was not available, the comparables were ordered to be excluded. We are of the opinion that there is no error in the approach adopted by the Tribunal, which is otherwise in line with the view taken by the coordinate bench. - HC

View Source

← Previous Next →

TP Adjustment - comparable selection - Clearly, since according ...

High Court Affirms Tribunal's Exclusion of Comparables for Transfer Pricing Due to Lack of Segmental Data Consistency.

September 26, 2023

Case Laws Income Tax HC

You may also like:

The Tribunal addressed various issues related to transfer pricing adjustments, including the selection of comparables, interest on trade receivables, and set-off of...

Tribunal held that Vishal Information Technologies Ltd. and Nucleus Net soft & GIS (India) Ltd. should be excluded from comparable selection for determining arm's length...

Transfer pricing adjustment - selection of comparable - Tribunal specified the aspects that may be kept in mind by the DRP while addressing the objections in respect to...

TP Adjustment - Comparable selection - determination of the arm’s length price (ALP) of international transactions - The appellant contested the inclusion of two...

The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

Comparable selection - Tribunal remanded issue of inclusion of companies to TPO to examine functional comparability after applying applicable filters. If functionally...

The Appellate Tribunal held that negative working capital adjustment cannot be made for a captive service provider. L&T Infotech Ltd. and Infosys Ltd. were excluded from...

Transfer Pricing Adjustments - Selection of the most appropriate method (MAM) for determining the arm's length price (ALP) - The assessee's choice to adopt the 'other...

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 Appellate Tribunal addressed various Transfer Pricing (TP) issues. Regarding software services, the Tribunal upheld the selection of comparables by the assessee over...

Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections...

The Tribunal meticulously analyzed each issue, heavily relying on precedent ITAT decisions and the specifics of the case presented. For the major contentious points,...

The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

TP Adjustment - comparable selection - The Tribunal upheld the inclusion of HSIL Limited in the list of comparables, considering its core business activities in...

The Income Tax Appellate Tribunal held that the export commission paid by the assessee to foreign agents in Korea and Indonesia for sales, marketing, and customer...

Quick Updates: