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ALP

Latest Articles


Revenue authorities lack jurisdiction to question commercial wisdom of taxpayer

Income Tax : Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cas...

October 19, 2024 663 Views 0 comment Print

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 3942 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 3111 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 20781 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 6555 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 1036 Views 0 comment Print


Latest Judiciary


Comparable Selection for Arm’s Length Price Relies on Functional Similarity

Income Tax : Delhi High Court remands Alcatel Lucent's transfer pricing case to ITAT, questioning selection of comparables in ALP determination...

November 3, 2024 315 Views 0 comment Print

High Brand Value, Large-Scale Operations & Lack of Segmented Data are valid Ground for Exclusion in ALP Determination

Income Tax : Delhi High Court judgment on Cadence Design's appeal against the ITAT order regarding transfer pricing comparables. Key findings o...

November 1, 2024 114 Views 0 comment Print

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 126 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 99 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 504 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 1650 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


Penalties for not Maintaining Documents for Specified Domestic Transactions

November 3, 2023 6555 Views 0 comment Print

Penalties for failing to maintain records of specified domestic transactions. Learn about arm’s length pricing & essential document requirements

Transfer Pricing Rules: Substantial Question of Law or Facts

October 23, 2023 1266 Views 0 comment Print

Explore landmark cases like SAP Labs vs. IT Officer, Evalueserve vs. Commissioner, and Softbrands vs. IT. Learn how the law and facts intersect in transfer pricing disputes.

TP adjustment deleted as ALP of ESOP expenses cannot be taken as NIL

October 11, 2023 1206 Views 0 comment Print

ITAT Mumbai held that TP adjustment in respect of international transaction of reimbursement of Employee Stock Option Plan (ESOP) Expenses deleted as Arm’s Length Price (ALP) of ESOP expenses cannot be taken as NIL.

Determination of ALP without applying methods prescribed u/s 92C is untenable

October 6, 2023 531 Views 0 comment Print

ITAT Mumbai held that the determination of Arm’s Length Price (ALP) without applying any methods as prescribed under section 92C(1) of the Income Tax Act by the TPO is not tenable in law.

TPO’s scope is limited to computing arm’s length price of a transaction

September 13, 2023 510 Views 0 comment Print

ITAT Delhi deleted TP adjustment on payment of model fee for export to AEs stating that scope of TPO is limited to determination of arm’s length price and TPO cannot adjudge commercial expediency of a transaction.

Delhi HC: TNMM Suitable Method for Indenting-Transactions ALP

August 6, 2023 411 Views 0 comment Print

Read the full text of the Delhi High Court judgment in the CIT vs. Sumitomo Corporation India Pvt Ltd case, concerning Assessment Years 2012-13 and 2013-14. TNMM found suitable for determining ALP for international indenting-transactions.

Arriving at Arm’s Length Price as NIL without giving contrary finding is unsustainable

July 1, 2023 969 Views 0 comment Print

ITAT Mumbai held that the TPO is not correct in arriving at the ALP as NIL on the ground that the need and benefit test is not satisfied by the assessee without giving any contrary findings with regard to the various documents including the TP study submitted by the assessee.

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

June 26, 2023 1650 Views 0 comment Print

Notification No. 46/2023-Income-Tax Dated: 26th June, 2023  regarding deemed arm’s length price for assessment year 2023-2024. Learn about the tolerance range for wholesale trading and other cases in international transactions or specified domestic transactions.  

Net Profit Margin Meeting Arm’s Length Price: Separate Addition not Sustainable

June 12, 2023 411 Views 0 comment Print

ITAT Bangalore held that if the net profit margin meets the Arm’s length price, then no separate addition needs to be made. Accordingly, TPO directed to delete the adjustment made towards Advertising Marketing Price (AMP) expenses.

ALP determined by ITAT can be challenged before HC for perversity & non observance of TP rules: SC

April 28, 2023 1215 Views 0 comment Print

Tribunal Decision determining ALP can be challenged on grounds of perversity & non observance of transfer pricing rules in individual cases

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