#Transfer Pricing
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1,377 articlesIncome Tax

Income Tax
Two pillar solution to tax challenges for digital economy – Part 2
Income Tax

Income Tax
Comparables with turnover less than Rs. 200 Cr cannot be compared with comparables having turnover more than Rs. 200 Cr.
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Income Tax
Companies with turnover of less than Rs. 200 crores cannot be compared with companies having turnover exceeding Rs. 200 crores
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Income Tax
TPO bound by decision of Jurisdictional HC if same has not been suspended or stayed
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Income Tax
An agreement shall reflect a true commercial substance of transaction
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TP: Unilateral action without agreement or understanding cannot be termed as a transaction
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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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Income Tax
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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Income Tax
Direct internal comparable price to be preferred over External CUP if available
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Income Tax
