TP - Arm's length price - CBDT instruction does not restrict the ...

CBDT Instruction Affirms AOs Can Refer Cases to TPO for Arm's Length Price Determination Beyond June 30, 2003.

January 7, 2011

Case Laws Income Tax AT

TP - Arm's length price - CBDT instruction does not restrict the powers of the AO from making references to the Transfer Pricing Officer after 30th June 2003

View Source

← Previous Next →

TP - Arm's length price - CBDT instruction does not restrict the ...

CBDT Instruction Affirms AOs Can Refer Cases to TPO for Arm's Length Price Determination Beyond June 30, 2003.

January 7, 2011

Case Laws Income Tax AT

You may also like:

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)...

Income Tax: TPO empowered to determine arm's length price for specified domestic transactions not referred by Assessing Officer or reported in audit report. Sections...

TP Adjustment - Determination of arm’s-length price - Law does not permit the TPO or DRP to determine the arm’s length price on estimation or adhoc basis. - Accordingly...

The ITAT held that the Transfer Pricing Officer (TPO) should consider comparables dealing in electronic products only, supported by a technical expert's certificate,...

Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

Jurisdiction of Transfer Pricing Officer - Suo motu, TPO cannot take cognizance of any international transaction for suggesting adjustment in the arm’ s length price,...

Determination of Arm’s Length Price – In the guise of determination of ALP, the TPO cannot question the business decision of payment and determine that no services were...

TPA - the jurisdiction and power of TPO is to determine arm's length price of Royalty and the order of TPO holding that the assessee had not derived any benefit under...

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

If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

TP Adjustment - determination of Arm's Length Price - intra group services transactions as Cross-charges - Documents submitted by the assessee do not conclusively...

ITAT addressed multiple transfer pricing issues in an international business case. TPO was directed to reassess arm's-length pricing for trading segment transactions,...

Determination of Arm's Length Price - Marketing agent arrangement –TPO was right in adding a markup as not independent and prudent entrepreneur will provide any service...

TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's Length Price is required to be determined for a transaction with specified persons in section 40A(2)(b)...

Quick Updates: