#Transfer Pricing
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1,301 articlesIncome Tax

Income Tax
Matter remanded to TPO as comparables were never examined before Trnasfer Pricing adjustments
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Mere Non-compliance with ICAI guidelines would not invite TP adjustment
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TP – No penalty for Using of Multiple year data to Compute ALP
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TP – Super profit companies cannot be considered as comparable
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TP – Super profit making or Restructured Companies cannot be taken as comparables for computing ALP
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TPO to consider objections of Assessee against the comparable selected by him to arrive at the ALP
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A.O. not to to demonstrate tax avoidance before invocation of TP provisions
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Glaxosmithkline Transfer Pricing Case Explained
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Matter remanded if additions are made by TPO without working capital adjustments
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TPO not justified in rejecting computation of ALP made by assessee by applying CUP method if all comparables are fairly unrelated
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No specific provisions for giving any opportunity to the assessee before reference to TPO
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IT – Draft Report on Retrospective Amendments Relating to Indirect Transfer
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AO cannot make Transfer Pricing adjustment unless recommended by TPO
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