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Transfer Pricing – Part 2 – Compliance and Assessment Procedures

Income Tax : Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs...

March 28, 2024 2106 Views 0 comment Print

Related Party Transactions: AS 18 vs. Transfer Pricing in India

Corporate Law : Explore intricacies of Related Party Transactions under AS 18 and Transfer Pricing in India. Understand control, influence, disclo...

January 3, 2024 1383 Views 0 comment Print

Understanding Domestic Transfer Pricing in India: Rules and Challenges

Income Tax : Explore the rules and challenges of Domestic Transfer Pricing (DTP) in India. Learn about legal definitions, threshold limits, app...

December 1, 2023 2532 Views 0 comment Print

Penalties for not Maintaining Documents for Specified Domestic Transactions

Income Tax : Penalties for failing to maintain records of specified domestic transactions. Learn about arm's length pricing & essential documen...

November 3, 2023 6162 Views 0 comment Print

Transfer Pricing Rules: Substantial Question of Law or Facts

Income Tax : Explore landmark cases like SAP Labs vs. IT Officer, Evalueserve vs. Commissioner, and Softbrands vs. IT. Learn how the law and fa...

October 23, 2023 1086 Views 0 comment Print


Latest News


Transfer Pricing Rules to incorporate “range concept” and “use of multi-year data”

Income Tax : Notification of Transfer Pricing Rules to incorporate range concept and use of multi-year data to reduce litigation on transfer pr...

October 20, 2015 1006 Views 0 comment Print


Latest Judiciary


AO Must Adhere to TPO’s ALP in International Transactions: Delhi HC

Income Tax : Delhi High Court rules AO can't deviate from Transfer Pricing Officer's determined Arm's Length Price (ALP) in international trans...

April 11, 2024 210 Views 0 comment Print

Management Service Fees paid to non-resident AEs is Deductible Expenses

Income Tax : Explore the ITAT Delhi ruling on the eligibility of management service fees paid to non-resident AEs under section 37(1) of the In...

March 21, 2024 174 Views 0 comment Print

Delhi HC remits ALP Determination Method matter to CIT(A)

Income Tax : Explore the judgment in Bombardier Transportation India Pvt. Ltd. Vs DCIT by Delhi High Court. The court remits the matter for det...

January 21, 2024 138 Views 0 comment Print

RPM Most Appropriate for ALP in Absence of Distributor’s Value Addition to Goods

Income Tax : Explore Delhi HC judgment in PCIT vs. Fujitsu India Ltd. for AY 2011-14, focusing on Transfer Pricing Method. Analysis of TNMM vs....

November 21, 2023 489 Views 0 comment Print

ALP of guarantee commission determined @0.3523% instead of 1.25%

Income Tax : ITAT Mumbai held that Arm’s Length Price (ALP) of guarantee commission was determined at the rate of 0.3523% instead of 1.25%....

November 20, 2023 480 Views 0 comment Print


Latest Notifications


Deemed Arm’s Length Price for Assessment Year 2023-2024

Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023  regarding deemed arm's length price for assessment year 2023-2024. Le...

June 26, 2023 1344 Views 0 comment Print

Notification on ALP determination in respect of wholesale trading

Income Tax : Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the ...

July 14, 2016 20633 Views 0 comment Print


Latest Posts in ALP

AO Must Adhere to TPO’s ALP in International Transactions: Delhi HC

April 11, 2024 210 Views 0 comment Print

Delhi High Court rules AO can’t deviate from Transfer Pricing Officer’s determined Arm’s Length Price (ALP) in international transactions, upholding assessee’s writ petition.

Transfer Pricing – Part 2 – Compliance and Assessment Procedures

March 28, 2024 2106 Views 0 comment Print

Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs, and penalties for non-compliance.

Management Service Fees paid to non-resident AEs is Deductible Expenses

March 21, 2024 174 Views 0 comment Print

Explore the ITAT Delhi ruling on the eligibility of management service fees paid to non-resident AEs under section 37(1) of the Income Tax Act in the case of Iris Worldwide Integrated Marketing Pvt. Ltd vs. DCIT.

Delhi HC remits ALP Determination Method matter to CIT(A)

January 21, 2024 138 Views 0 comment Print

Explore the judgment in Bombardier Transportation India Pvt. Ltd. Vs DCIT by Delhi High Court. The court remits the matter for determining the Arm’s Length Price (ALP) method.

Related Party Transactions: AS 18 vs. Transfer Pricing in India

January 3, 2024 1383 Views 0 comment Print

Explore intricacies of Related Party Transactions under AS 18 and Transfer Pricing in India. Understand control, influence, disclosure requirements and how arm’s length principle is applied.

Understanding Domestic Transfer Pricing in India: Rules and Challenges

December 1, 2023 2532 Views 0 comment Print

Explore the rules and challenges of Domestic Transfer Pricing (DTP) in India. Learn about legal definitions, threshold limits, applicability, Arm’s Length Price, documentation, issues, and techniques.

RPM Most Appropriate for ALP in Absence of Distributor’s Value Addition to Goods

November 21, 2023 489 Views 0 comment Print

Explore Delhi HC judgment in PCIT vs. Fujitsu India Ltd. for AY 2011-14, focusing on Transfer Pricing Method. Analysis of TNMM vs. RPM with key findings. Insights and conclusion provided.

ALP of guarantee commission determined @0.3523% instead of 1.25%

November 20, 2023 480 Views 0 comment Print

ITAT Mumbai held that Arm’s Length Price (ALP) of guarantee commission was determined at the rate of 0.3523% instead of 1.25%.

Delhi HC Upholds ITAT’s Decision on Comparables for Arm’s Length Price

November 14, 2023 504 Views 0 comment Print

Delhi High Court supports ITAT’s verdict on the selection of comparables for determining the Arm’s Length Price of an international transaction. Get insights on PCIT vs Chrys Capital

CUP Method Rejection Unwarranted for Uniform Hourly Charges to AEs & Third Parties

November 4, 2023 216 Views 0 comment Print

ITAT that as long as the charges for hourly services provided by appellant were uniform to AEs and third parties, rejection of CUP method was unwarranted.