#Transfer Pricing
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1,304 articlesIncome Tax

Income Tax
Determination of ALP without applying methods prescribed u/s 92C is untenable
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Income Tax
Indian subsidiary operating in independent manner doesn’t constitute PE
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Income Tax
ITAT deletes ALP adjustment as it falls within tolerance band of +/- 5%
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TPO’s scope is limited to computing arm’s length price of a transaction
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Specified domestic transactions adjustment invalid after 01.04.2017
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Income Tax
Commission by Jetair Pvt. Ltd. to Jet Airways (India): TP Provisiosns not apply
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Income Tax
Royalty for technology use should be aggregated with other international transactions in manufacturing segment
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TNMM is most appropriate method in absence of CUP which is applicable in intangibles
Income Tax

Income Tax
TPO order passed beyond time limit prescribed u/s 92CA(3) is barred by limitation
Income Tax

Income Tax
CBDT extends applicability of Safe Harbour rules to AY 2023-24
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Income Tax
Delhi HC: TNMM Suitable Method for Indenting-Transactions ALP
Income Tax

Income Tax
Only international and not entity level transactions covered in transfer pricing adjustment
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Income Tax
HC Upholds Exclusion of Comparables Due to Functional Dissimilarity & Amalgamation
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Income Tax
