#Transfer Pricing
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1,301 articlesIncome Tax
Income Tax
ALP of loan transaction has to be determined as per CUP & LIBOR
Income Tax
Income Tax
No question of law before HC if Tribunal rejects comparables selected by TPO after giving detailed reasons
Income Tax
Income Tax
TP – Circular on Identification of Contract R&D Service Provider With Insignificant Risk & Application of Profit Split Method
Income Tax
Income Tax
TPO may use date which may not have been available to the assessee at the time of preparation of statutory transfer pricing study/documentation
Income Tax
Income Tax
TP adjustment without considering business structure of assessee not maintainable
Income Tax
Income Tax
Companies, whose employees or directors are involved in fraud, should not be accepted as comparable
Income Tax
Income Tax
Landmark ITAT Special Bench Verdict On Transfer Pricing Of advertisement, marketing & sales promotion expenses
Income Tax
Income Tax
TPO can select method other then the one selected by Assessee to determine true income
Income Tax
Income Tax
Method adopted by Assessee for determining ALP cannot be rejected without showing fallacies in method adopted by Assessee
Income Tax
Income Tax
No TP adjustmentas for expenses disallowed by assessee sou-motu
Income Tax
Income Tax
TPO cannot determine ALP of Project at NIL if Assessee submit all relevant documents & bills
Income Tax
Income Tax
TPO must justify arm’s length margin fixed by it
Income Tax
Income Tax
Disallowance U/s. 40A(2) is not required to be made for TP adjustments
Income Tax
Income Tax
