ALP

Transfer Pricing: Analysis of Income-tax (16th Amendment) Rules, 2015

Income Tax - The Finance (No. 2) Act, 2014 proposed to introduce a more streamlined method to compute Arm’s Length Price (ALP) in a situation where more than one price is determined, on adoption of Most Appropriate Method(MAM). The first and second provisos were made redundant for all transactions undertaken on or after 01/04/2014. This was done so ...

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Calculation of Arm’s Length Price-Section 92C of Income Tax Act, 1961

Income Tax - A transaction in which the buyers and sellers of a product act independently and have no relationship to each other. The concept of an arm's length transaction is to ensure that both parties in the deal are acting in their own self interest and are not subject to any pressure or duress from the other party...

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Filing of return of income, definition of international transaction, tolerance band for ALP, penalties and reassessment in transfer pricing cases

Income Tax - Section 139 of the Act provides for due date of filing return of income in case of various categories of persons. In addition to filing of return of income, the assesses who have undertaken international transactions are also required to prepare and file a Transfer Pricing report in Form 3CEB, as per Section 92E of the Act, before the due...

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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 pricing issues....

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Associated Enterprises of assessee cannot be taken as comparable for determining ALP as per CUP method

Gemstone Glass Pvt. Ltd Vs Joint Commissioner of Income Tax (ITAT Ahmedabad) - The ITAT Ahmedabad in the case of Gemstone Glass Pvt. Ltd vs. JCIT held that when an associated enterprise is taken as comparable then CUP method cannot be adopted for determining Arm Length Price irrespective of the fact that the associated enterprise taken as comparable is resident or non-resident...

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Functionally dissimilar company cannot be considered as comparable for computation of ALP

M/s. AT & T Global Business Services India Pvt.Ltd. Vs ITO (ITAT Bangalore) - In case of M/s. AT & T Global Business Services India Pvt.Ltd. VS. ITO , assessee-company, engaged in business of software development and providing application services to its AE. TPO on basis of mean margin earned by his own set of comparables...

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If there is International transaction, Arm’s Length Price would be decided using international commercial principle.

CIT Vs M/s Cotton Naturals (I) Pvt. Ltd. (Delhi High Court) - Assessee had given the loan to the associate enterprise in U.S.D. and in such a situation when the transaction was in foreign currency, and the transaction was an international transactions, then the transaction would have to be looked upon by applying the commercial principles in regard to internat...

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Notification on ALP determination in respect of wholesale trading

Notification No. 57/2016-Income Tax - (14/07/2016) - Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the price at which the international transaction or specified domestic transaction has actually been undertaken does not exceed one percent of the latter in respect of wholes...

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Recent Posts in "ALP"

Notification on ALP determination in respect of wholesale trading

Notification No. 57/2016-Income Tax (14/07/2016)

Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the price at which the international transaction or specified domestic transaction has actually been undertaken does not exceed one percent of the latter in respect of wholesale trading and three percent.of the lat...

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Associated Enterprises of assessee cannot be taken as comparable for determining ALP as per CUP method

Gemstone Glass Pvt. Ltd Vs Joint Commissioner of Income Tax (ITAT Ahmedabad)

The ITAT Ahmedabad in the case of Gemstone Glass Pvt. Ltd vs. JCIT held that when an associated enterprise is taken as comparable then CUP method cannot be adopted for determining Arm Length Price irrespective of the fact that the associated enterprise taken as comparable is resident or non-resident....

Read More

Transfer Pricing: Analysis of Income-tax (16th Amendment) Rules, 2015

The Finance (No. 2) Act, 2014 proposed to introduce a more streamlined method to compute Arm’s Length Price (ALP) in a situation where more than one price is determined, on adoption of Most Appropriate Method(MAM). The first and second provisos were made redundant for all transactions undertaken on or after 01/04/2014. This was done so ...

Read More
Posted Under: Income Tax |

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

Notification of Transfer Pricing Rules to incorporate range concept and use of multi-year data to reduce litigation on transfer pricing issues....

Read More
Posted Under: Income Tax |

Functionally dissimilar company cannot be considered as comparable for computation of ALP

M/s. AT & T Global Business Services India Pvt.Ltd. Vs ITO (ITAT Bangalore)

In case of M/s. AT & T Global Business Services India Pvt.Ltd. VS. ITO , assessee-company, engaged in business of software development and providing application services to its AE. TPO on basis of mean margin earned by his own set of comparables...

Read More

Calculation of Arm’s Length Price-Section 92C of Income Tax Act, 1961

A transaction in which the buyers and sellers of a product act independently and have no relationship to each other. The concept of an arm's length transaction is to ensure that both parties in the deal are acting in their own self interest and are not subject to any pressure or duress from the other party...

Read More
Posted Under: Income Tax |

If there is International transaction, Arm’s Length Price would be decided using international commercial principle.

CIT Vs M/s Cotton Naturals (I) Pvt. Ltd. (Delhi High Court)

Assessee had given the loan to the associate enterprise in U.S.D. and in such a situation when the transaction was in foreign currency, and the transaction was an international transactions, then the transaction would have to be looked upon by applying the commercial principles in regard to international transactions....

Read More

Filing of return of income, definition of international transaction, tolerance band for ALP, penalties and reassessment in transfer pricing cases

Section 139 of the Act provides for due date of filing return of income in case of various categories of persons. In addition to filing of return of income, the assesses who have undertaken international transactions are also required to prepare and file a Transfer Pricing report in Form 3CEB, as per Section 92E of the Act, before the due...

Read More
Posted Under: Income Tax |

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