#Transfer Pricing
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1,301 articlesIncome Tax
Income Tax
CBDT Clarifications on Functional Profile of Development Centres engaged in Contract R&D Services with insignificant risk
Income Tax
Income Tax
Transfer Pricing – Important principles on turnover filter & comparison explained
Income Tax
Income Tax
Transfer Pricing – If more than one price is determined by the most appropriate method, the ALP has to be the arithmetical mean of such prices
Income Tax
Income Tax
No Transfer Pricing adjustments can be made if actual transaction price is within safe harbour limit of +/- 5%
Income Tax
Income Tax
TP -Giant companies are not comparable with smaller pygmy companies
Income Tax
Income Tax
Transfer Pricing – Even Business Advance Has To Be At Libor ALP – ITAT Mumbai
Income Tax
Income Tax
Comparables cannot be rejected simply because they are loss or high profit making comparables
Income Tax
Income Tax
In ALP computation TPO to consider forex gain which is part of operating income of Assessee
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Income Tax
In Computation of ALP, company having large related party transactions or being functionally different from assessee cannot be taken as comparable
Income Tax
Income Tax
If only one comparable is considered to determine ALP, benefit of ± 5 percent as provided by proviso to S. 92C(2) will not be available
Income Tax
Income Tax
ALP cannot be determined arbitrarily, It must be by one of methods prescribed U/s. 92C, RW rule 10B
Income Tax
Income Tax
Transfer pricing – RBI approval do not partake the character of ALP
Income Tax
Income Tax
TP – Rate approved or deemed to be approved by RBI has to be considered as ALP
Income Tax
Income Tax
