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 October 2023 Year 2023 This

TP Adjustment - payment of technical knowhow fees - benchmarking ...

Case Laws     Income Tax

October 19, 2023

TP Adjustment - payment of technical knowhow fees - benchmarking of the transaction - Intragroup services or for that matter any international transaction is required to be benchmarked each year based on the facts and circumstances prevailing in that year considering the economic conditions. Therefore, the findings of the previous year will have only persuasive value, if any, while deciding the transfer pricing adjustment for any year. - AT

View Source

 


 

You may also like:

  1. 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...

  2. Disallowance of payments made for royalty and technical know-how received - Accepted Most appropriate method for benchmarking the manufacturing segment as TNNM -...

  3. TP Adjustment - Technical know-how fees paid by Appellant to its Associated Enterprise - For the year under consideration (AY 204-15), we notice that TPO has applied...

  4. Transfer Pricing Adjustment - TPO's reliance on loan data from the US and Europe for benchmarking is inappropriate given Bahrain's distinct economic environment and...

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

  6. The ITAT Ahmedabad addressed Transfer Pricing (TP) adjustments, focusing on royalty, management fees, and IT allocation costs. The tribunal upheld the use of the...

  7. TP adjustment in respect of franchise fee - prudence of expenditure - TPO cannot step into the shoes of assessee to decide prudence of expenditure. The TPO failed to...

  8. TP adjustment on account of back-to-back counter bank guarantee - TPO, by considering the rate charged by Bank of Baroda for issuance of guarantee against 100% counter...

  9. TP Adjustment - tested party - No infirmity in the order of the learned CIT(A) in directing the assessee to adopt the foreign associated enterprise as tested party with...

  10. The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should...

  11. 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...

  12. 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...

  13. Valuation - technical knowhow, drawing and design fee and engineering services fee, are not includable in the transaction value of the imported goods - AT

  14. TP adjustment - benchmarking of international transaction of import of raw materials - the TP adjustments in respect of this transaction should be restricted in terms of...

  15. Payment to overseas institution as fees for awarding the degrees, supplying books and course material – There is no transfer of any technical know-how or technical...

 

Quick Updates:Latest Updates