#Transfer Pricing
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1,377 articlesIncome Tax
Income Tax
Only international and not entity level transactions covered in transfer pricing adjustment
Income Tax
Income Tax
HC Upholds Exclusion of Comparables Due to Functional Dissimilarity & Amalgamation
Income Tax
Income Tax
Adjustment of notional interest unsustainable as credit period extended to even non-associated enterprises without interest
Income Tax
Income Tax
Voith Siemens Hydro Private Limited Vs ACIT: Analysis of Transfer Pricing Proceedings | ITAT Delhi
Income Tax
Income Tax
Benchmarking corporate guarantee fees based on bank guarantee rates is incorrect
Income Tax
Income Tax
Most appropriate method for determining Arm’s Length Price is internal CUP
Income Tax
Income Tax
Time-Barred TPO Order Renders Assessee Ineligible
Income Tax
Income Tax
AO Can Refer case To TPO Only After Selecting Case For Scrutiny Assessment: Bombay HC
Income Tax
Income Tax
Rate at which loan taken by Appellant cannot be taken as internal CUP to benchmark loan given to AE
Income Tax
Income Tax
Arriving at Arm’s Length Price as NIL without giving contrary finding is unsustainable
Income Tax
Income Tax
Transfer pricing adjustment @0.6% as arm’s length rate for corporate guarantee fee directed
Income Tax
Income Tax
Comparable having loss in three successive assessment years is persistent loss making company
Income Tax
Income Tax
Deemed Arm’s Length Price for Assessment Year 2023-2024
Income Tax
Income Tax
