#Transfer Pricing
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1,377 articlesIncome Tax

Income Tax
TNMM is a right method to arrive at ALP when assessee have not taken Substantial Risks
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Domestic Transfer Pricing – The Current Scenario
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TP adjustments not applicable on transactions between Head Office & Branch Office
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Marketing & liasoning services can’t be equated with advisory services for ALP adjustment
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Functionally Different Companies can’t be compared under transfer Pricing
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Income Tax
BEPS Action Plan 13 – Complete turnaround of documentation structure!!
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Income Tax
Adjustment for variation in closing stock necessary for correct application of TNMM
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Comparable which is to be considered as a benchmark for comparing with comparable company should belong to year under consideration
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Comparable Selected in TP study should be functionally same & not necessarily to be identical
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Prevent artificial avoidance of permanent establishment status
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Draft scheme of proposed rules for computation of ALP
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Income Tax
Arms Length Price – TNMM PLI Data only regard AE not Whole
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Income Tax
Transfer Pricing : Exclusion of comparable on the basis of High Profit
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Income Tax
