#Transfer Pricing
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1,377 articlesIncome Tax

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Mandatory e-filling of Audit report u/s. 44AB, 92E & 115JB
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TP- Comparability of High End Cos with Low End Cos in ITES/ BPO Sector
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Transfer Pricing -Domestic leg of cross-border deal, even if consequential to overseas deal by parent AE, not covered if terms not dictated by parent AE
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OECD – Draft handbook on transfer pricing risk assessment
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New time limits for completion of assessment or reassessment U/s 153 / 153B in cases where reference is made to TPO
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Balance needs to be maintained between the principle of consistency and the rule of res judicata
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CBDT Clarifications on Functional Profile of Development Centres engaged in Contract R&D Services with insignificant risk
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Transfer Pricing – Important principles on turnover filter & comparison explained
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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
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No Transfer Pricing adjustments can be made if actual transaction price is within safe harbour limit of +/- 5%
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TP -Giant companies are not comparable with smaller pygmy companies
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Transfer Pricing – Even Business Advance Has To Be At Libor ALP – ITAT Mumbai
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Comparables cannot be rejected simply because they are loss or high profit making comparables
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