Transfer pricing adjustment - arm's length price of broking ...

Transfer Pricing Officer Rejects TNMM, Applies CUP Method; Marketing Costs Adjusted, Error Trading Losses Allowed.

July 17, 2024

Case Laws Income Tax AT

Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for comparability - TPO rejected TNMM, applied CUP method - directed to consider both overseas and domestic clients while applying CUP method. No adjustment of marketing cost while applying CUP method, not granting adjustment of research cost and volume - directed to allow 40% adjustment on marketing and research cost. Computing upward adjustment by considering addition instead of rectified amount - issue restored to AO for giving effect as per TPO's rectification order. Disallowance of net loss incurred on error trading transactions - directed to allow as incidental to assessee's broking business. Disallowance u/s 14A - issue remanded to AO to examine disallowance and assessee to substantiate claim.

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Transfer pricing adjustment - arm's length price of broking ...

Transfer Pricing Officer Rejects TNMM, Applies CUP Method; Marketing Costs Adjusted, Error Trading Losses Allowed.

July 17, 2024

Case Laws Income Tax AT

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