#Transfer Pricing
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1,377 articlesIncome Tax
Income Tax
In Computation of ALP, company having large related party transactions or being functionally different from assessee cannot be taken as comparable
Income Tax
Income Tax
If only one comparable is considered to determine ALP, benefit of ± 5 percent as provided by proviso to S. 92C(2) will not be available
Income Tax
Income Tax
ALP cannot be determined arbitrarily, It must be by one of methods prescribed U/s. 92C, RW rule 10B
Income Tax
Income Tax
Transfer pricing – RBI approval do not partake the character of ALP
Income Tax
Income Tax
TP – Rate approved or deemed to be approved by RBI has to be considered as ALP
Income Tax
Income Tax
TPO can take domestic unrelated parties as comparables if Assessee having similar transactions with them
Income Tax
Income Tax
ALP of loan transaction has to be determined as per CUP & LIBOR
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Income Tax
No question of law before HC if Tribunal rejects comparables selected by TPO after giving detailed reasons
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Income Tax
TP – Circular on Identification of Contract R&D Service Provider With Insignificant Risk & Application of Profit Split Method
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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
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Income Tax
TP adjustment without considering business structure of assessee not maintainable
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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
