rule 10b

It is mandatory for the assessee to follow one of the methods prescribed in Section 92C of the Income Tax Act, 1961 read with Rule 10B of the Income Tax Rules, 1962 and demonstrate that the international transactions entered with the associated enterprise are at arm’s length. Full Article

In the case of Schefenacker Motherson Ltd v. ITO, ITA No. 4459/DEL/07 for AY 2003-04 and schefenacker Motherson Ltd v. DCIT, ITA No.4460/DEL/07 for AY 2004-05, the Delhi Bench of the Income-tax Appellate Tribunal (the Tribunal), held that cash profit on sales “CP/Sales” or cash profit on total cost excluding depreciation “CP/TCdep” can be adopted as an appropriate profit level indicator (PLI) under Transactional Net Margin Method (TNMM), to adjust for material d.. Full Article

Ranbaxy Laboratories Ltd. v. Additional Commissioner of Income-tax Section 92C, read with section 92CA, of the Income-tax Act, 1961 - Transfer pricing - Computation of Arm's length price - Assessment year 2004-05 - Whether Assessing Officer in light of Instruction No. 3 of 2003, dated 20-5-2003 of CBDT is duty bound to refer matter to transfer pricing officer of international transaction exceeding Rs. 5 crores, having regard to purpose of specialized cell created by reve.. Full Article