#Transfer Pricing
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1,304 articlesIncome Tax
Income Tax
ITAT Hyderabad Upholds Rs 1.33 Crore TP Adjustment on Hammond Power Over Service Fees
Income Tax
Income Tax
Transfer Pricing Methods: Internal CPM: Domestic & Export Market are not comparable
Income Tax
Income Tax
Commission to Amway Distributors Not AMP Expense for Transfer Pricing: ITAT Delhi
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Resale Price Method most appropriate as assessee acts as distributor and makes no value addition
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Existence of International Transaction Must Be Analyzed Before Benchmarking AMP Expense
Income Tax
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Amendment of Safe Harbour Rules for AY 2025-26 under Section 92CB
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Cost Allocation and Transfer Pricing – ITAT Bangalore Ruling
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Future of International Taxation: OECD Global Minimum Tax
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Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction
Income Tax
Income Tax
Indian Subsidiary Not a Dependent Agency PE if Transactions Are Subject to TPO Adjustment
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Comparable cannot be excluded in Absence of Persistent Losses: ITAT Delhi
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Protective Addition Unsustainable if Substantial Addition is Confirmed or Settled: ITAT Bangalore
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Income Tax
Negative Margins & Functional Differences: ITAT Upholds Comparable Exclusion
Income Tax
Income Tax
