Transfer Pricing Adjustments - The Tribunal upheld the Ld. DRP's ...

Tribunal Upholds DRP Directions on Transfer Pricing; Orders Compliance on Working Capital Adjustments by Assessing Officer.

February 15, 2024

Case Laws Income Tax AT

Transfer Pricing Adjustments - The Tribunal upheld the Ld. DRP's directions on various objections raised by the taxpayer, including the consideration of multiple-year data, peculiar economic conditions, abnormal business loss, under-utilization of capacity, and treatment of expenses. - However, the ITAT found that the Assessing Officer (AO) had not fully complied with the Ld. DRP's directions, specifically regarding working capital adjustments. It directed the AO/TPO to consider all of the Ld. DRP's directions while drafting the final assessment order. - Matter restored back.

View Source

← Previous Next →

Transfer Pricing Adjustments - The Tribunal upheld the Ld. DRP's ...

Tribunal Upholds DRP Directions on Transfer Pricing; Orders Compliance on Working Capital Adjustments by Assessing Officer.

February 15, 2024

Case Laws Income Tax AT

You may also like:

Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

Final assessment order passed u/s 143(3) read with Section 144C(13) subsequent to Dispute Resolution Panel (DRP)/Transfer Pricing Officer (TPO) directions deemed invalid...

The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

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

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

The Tribunal upheld the validity of the assessment order. Despite the alleged violation of statutory procedure u/s 144B, the Tribunal found that the assessment...

HC ruled that time limits under Section 144C(13) for completing assessments following DRP directions are mandatory, not directory. The AO must pass orders within one...

Oppression and Mismanagement - The Appellate Tribunal highlighted the absence of reasoning in the impugned order, especially regarding the direction for an independent...

Validity of the final assessment order due to non-service of the Dispute Resolution Panel’s (DRP) directions - AR candidly admitted before the Tribunal that, on the...

DRP directions without a valid computer-generated Document Identification Number (DIN) allotted and quoted in the body of the order are invalid and deemed never issued....

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

Powers of the DRP u/s 144C(8) - Tribunal was not right in holding that the DRP exceeded its jurisdiction in passing the order. In any event, the order passed by the DRP...

The Principal Commissioner or Commissioner having jurisdiction over transfer pricing matters has been empowered, effective April 1, 2022, to invoke revisionary action...

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

Quick Updates: