#Transfer Pricing
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1,377 articlesIncome 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
Revenue cannot be aggregated for determining ALP of software development services for two different sectors
Income Tax
Income Tax
TP adjustment for intra group services not sustainable where receipt of services & its benefits are beyond any doubt
Income Tax
Income Tax
TP- operating cost should be calculated by adjusting abnormal cost incurred on account of Start-up Company
Income Tax
Income Tax
Mere fact that an entity makes extremely high profits/losses does not lead to its exclusion from list of comparables for ALP determination
Income Tax
Income Tax
OECD takes further steps to putting an end to offshore tax evasion
Income Tax
Income Tax
Recovery of expenses beyond normal period was in the nature of deemed loan in the hands of AEs and require TP adjustment
Income Tax
Income Tax
Assessee making periodically RBI approved royalty payments to its AE, TPO not justified in determining ALP at Nil
Income Tax
Income Tax
Royalty Payments and Transfer Pricing Issues
Income Tax
Income Tax
Interest free loans extended as quasi capital to 100% subsidiary cannot have nil ALP
Income Tax
Income Tax
Allowing credit period to the AE has to be considered along with main international transaction of sale of goods
Income Tax
Income Tax
Transfer Pricing- Companies having abnormal cost cannot be taken as comparable
Income Tax
Income Tax
