#Transfer Pricing
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1,301 articlesIncome Tax
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Transfer Pricing – In Realm of evolution – Part I
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For Determination of Arm’s Length Price 5% tolerance band not standard deduction
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Transfer Pricing Regulations made applicable to domestic transactions if value exceeds Rs. 5 Cr.
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Examination by Transfer Pricing Officer of international transactions not reported by Assessee
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Transfer pricing – Non-charging of interest in the controlled transactions is comparable with that of non-charging from the uncontrolled transactions, no transfer pricing adjustment can be made on this count
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Payment of commission to Indian agent at arm’s length price does not relieve non-resident from further attribution of profits to PE in India
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Transfer Pricing Concept & The Law in India
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Transfer Pricing – TPO can rely on ‘contemporaneous’ data even if not available at specified date – ITAT Bangalore
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Without reference assumption of jurisdiction by Transfer Pricing Officer in working out arm’s length price not justified
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Despite Dependence, Arms’ Length Agent is Not Permanent Establishment (PE)
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Transfer Pricing – Non-Reference To TPO Renders Order ‘Erroneous’ and prejudicial to revenue
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Transfer Pricing – ALP of Interest-Free Loan – ITAT Delhi Explains Law
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No functions, assets and risks analysis is required before AY 2002-03 for determination of profits attributable to dependent agent permanent establishment; no further attribution if dependent agent paid arm’s length commission
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