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ALP

Latest Articles


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 3777 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 2913 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 17955 Views 1 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 6501 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 1224 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 1033 Views 0 comment Print


Latest Judiciary


Indian Subsidiary Compensated at ALP Not a Dependent Agent PE: Delhi HC

Income Tax : Delhi HC rules Krones' Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority's appeal....

October 11, 2024 105 Views 0 comment Print

TPO must justify altering the previously accepted position on comparables

Income Tax : Punjab & Haryana High Court rules comparable used in ALP determination must be justified. The court dismisses Revenue's appeal, up...

September 24, 2024 78 Views 0 comment Print

Delhi HC ruling on transfer pricing provisions concerning intra-group services

Income Tax : Read the Delhi High Court judgment on PCIT vs Mercer Consulting India Pvt. Ltd. regarding transfer pricing provisions and intra-gr...

May 8, 2024 483 Views 0 comment Print

Consider Volume Discount & Geographic Price Variation in TP Adjustment: ITAT Ahmedabad

Income Tax : Ahmedabad ITAT's order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. De...

May 8, 2024 330 Views 0 comment Print

Ahmedabad ITAT Clarifies Letter of Credit vs. Bank Guarantee in Transfer Pricing Dispute

Income Tax : In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Co...

May 8, 2024 966 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 1635 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 20696 Views 0 comment Print


Latest Posts in ALP

Indian Subsidiary Compensated at ALP Not a Dependent Agent PE: Delhi HC

October 11, 2024 105 Views 0 comment Print

Delhi HC rules Krones’ Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority’s appeal.

TPO must justify altering the previously accepted position on comparables

September 24, 2024 78 Views 0 comment Print

Punjab & Haryana High Court rules comparable used in ALP determination must be justified. The court dismisses Revenue’s appeal, upholding ITAT’s ruling.

Delhi HC ruling on transfer pricing provisions concerning intra-group services

May 8, 2024 483 Views 0 comment Print

Read the Delhi High Court judgment on PCIT vs Mercer Consulting India Pvt. Ltd. regarding transfer pricing provisions and intra-group services.

Consider Volume Discount & Geographic Price Variation in TP Adjustment: ITAT Ahmedabad

May 8, 2024 330 Views 0 comment Print

Ahmedabad ITAT’s order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. Detailed analysis provided.

Ahmedabad ITAT Clarifies Letter of Credit vs. Bank Guarantee in Transfer Pricing Dispute

May 8, 2024 966 Views 0 comment Print

In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Corporate Guarantee, resolving disallowance disputes.

Bullion Purchases: LBMA Rates vs. KITCO and Reuters for ALP

May 6, 2024 318 Views 0 comment Print

ITAT considered the justification provided by the assessee, which referenced KITCO and Reuters databases for determining transaction prices. However, the Transfer Pricing Officer (TPO) argued that the London Bullion Market Association (LBMA) should be the primary source for estimating bullion trading prices.

ITAT Directs TPO/AO to Delete Adjustment on Export Commission Payment ALP

May 5, 2024 261 Views 0 comment Print

In the case of Honda Motorcycle & Scooter India Pvt Ltd vs. ACIT, ITAT Delhi directed the Transfer Pricing Officer (TPO) and Assessing Officer (AO) to delete the adjustment made on account of the arm’s length price (ALP) of export commission payment.

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

April 11, 2024 639 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 3777 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 492 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.

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