#Transfer Pricing
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1,304 articlesIncome Tax
Income Tax
Transfer Pricing: Captive unit bearing limited risk cannot be compared with a giant company having full fledged risk
Income Tax
Income Tax
Time limit u/s 92CA (3A) being mandatory, no transfer pricing adjustment sustainable on time barred TPO order
Income Tax
Income Tax
No estoppels in law for correctness, inadvertently included comparable may be argued in later proceedings
Income Tax
Income Tax
Only Functionally Comparable Company should be compared for applying margin percentage
Income Tax
Income Tax
Presumption of existence of an international transaction not allowed in transfer pricing provision
Income Tax
Income Tax
Internal comparability is a preferred method in transfer pricing study where within company profit margin data with third parties available
Income Tax
Income Tax
TP provisions requires comparison of a controlled transaction with uncontrolled transaction, comparison within two controlled transaction is immaterial
Income Tax
Income Tax
Referring case to TPO – now become tougher for Dept
Income Tax
Income Tax
Depreciation should be considered for evaluating operating results of comparables
Income Tax
Income Tax
Associated Enterprises of assessee cannot be taken as comparable for determining ALP as per CUP method
Income Tax
Income Tax
Interpretation of Notification-83, 2015 in respect of Arm's Length Range Concept
Income Tax
Income Tax
Mere profitability, responsible for enhancement of profits, does not indicate that transaction is at an ALP
Income Tax
Income Tax
Transfer Pricing: Analysis of Income-tax (16th Amendment) Rules, 2015
Income Tax
Income Tax
