#Transfer Pricing
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1,301 articlesIncome Tax

Income Tax
TP: Depreciation is Operating & revenue from Sale of Asset is non-operating in nature
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TP adjustment without applying any prescribed benchmarking method is unsustainable
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Transfer Pricing: Working capital adjustment should be allowed on actuals
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Comparable having extraordinary financial event of M&A cannot be considered for TP analysis
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No further income attributable to a PE in India, if PE been remunerated at ALP
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Income Tax
Rate at which electricity company sells to customers should be taken as CUP
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Direct internal comparable price to be preferred over External CUP if available
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Provision for doubtful and bad debts to be considered as operating expense in TP calculations
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Transfer Pricing as a means to minimize Tax
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TNMM is most appropriate method if transactions are relatable & interrelated
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No TP Adjustment for Increase in brand value due to use of foreign AEs brand name
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Income Tax
Transfer pricing adjustment on account of alleged guarantee transaction
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Income Tax
CBDT Extends Time Limits for Tax/TP Audit/ITR Filing – AY 2021-22
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Income Tax
