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Recently Learned CA T.P. Ostwal has commented on Transfer Pricing issues while addressing a WEBCAT for ICAI on “Overview of Transfer Pricing” that ” TP is not art, its not science….. its magic!” He further point out the following deficiencies :-
–No proper comparables available
–Grossly improper comparables being used
–No clear method or quantification for adjustments
–Cherry-picking of comparables by all parties
–Disparate Data sources are a bone of contention
–Documentation requirement overload
–Lack of knowledge & skill-set
–Concepts such as ‘location savings’ not even acknowledged
–Growth of “intangible” economy ignored completely
–Overburdening of taxpayer
Download Presentation from CA T.P. Ostwal on “Overview of Transfer Pricing”
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Am required to issue report in Form 3CEB for a few clients of mine who are basically traders, hit by SDT. When one goes through the guidance note published by ICAI ( updated upto August 2013), one finds that in the matter of SDT, it is only the transactions appearing on the debit side of the P & L account which attract reporting. However, the clause 25, part C of the revised Form 3CEB asks for amounts paid/received or payable/receivable which gives impression that the report has to be furnished for sales transactions too, such sales made to related parties. The methods for computing ALP also keep discussing sales . Can anybody please clear whether sales made to related parties are also subject to ALP mechanism and reporting???
After long deliberation I have concluded that the thing called ALP is actually the same as GOD. There are too many similarities between them;
In respect of both, people have a firm belief but without any proof that they actually exist.
In respect of both, people have their own explanations and everyone claims that his definition is the correct one and that of all others are false.
In case of both, what people have said have created never ending conflicts.
🙂