#Transfer Pricing
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1,304 articlesIncome Tax
Income Tax
Analysis of Final Rules on ‘Range Concept’ &‘Multiple year data’ in Transfer Pricing provisions
Income Tax
Income Tax
Tolerance margin (+/-) 5% u/s 92C (2) available only where variation between ALP and Actual price limited to this range
Income Tax
Income Tax
Transfer Pricing Rules to incorporate “range concept” and “use of multi-year data”
Income Tax
Income Tax
CBDT notification on Transfer Pricing Rules to incorporate range concept and use of multi-year data
Income Tax
Income Tax
Revised Guidance for Implementation of Transfer Pricing Provisions
Income Tax
Income Tax
Company with very high operating margin can be included in list of comparable after proper justification/investigation
Income Tax
Income Tax
Change in method of ALP in transfer pricing adjustment not permitted on same set of facts
Income Tax
Income Tax
Functionally dissimilar company cannot be considered as comparable for computation of ALP
Income Tax
Income Tax
Comparable transactions/entity must be selected based on similarity with controlled transaction/entity
Income Tax
Income Tax
When both AE and Indian enterprise are making contribution then PSM is to be follow for determination of ALP
Income Tax
Income Tax
Benchmarking Under Transfer Pricing
Income Tax
Income Tax
TP: Lower turnover cannot be sole basis for exclusion
Income Tax
Income Tax
ALP not to be computed if transaction is not with associated enterprise
Income Tax
Income Tax
