#Transfer Pricing
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1,377 articlesIncome 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
Commissioner cannot revise order passed by TPO u/s. 92CA(3)
Income Tax
Income Tax
Matter remanded to TPO as comparables were never examined before Trnasfer Pricing adjustments
Income Tax
Income Tax
Mere Non-compliance with ICAI guidelines would not invite TP adjustment
Income Tax
Income Tax
TP – No penalty for Using of Multiple year data to Compute ALP
Income Tax
Income Tax
TP – Super profit companies cannot be considered as comparable
Income Tax
Income Tax
TP – Super profit making or Restructured Companies cannot be taken as comparables for computing ALP
Income Tax
Income Tax
TPO to consider objections of Assessee against the comparable selected by him to arrive at the ALP
Income Tax
Income Tax
A.O. not to to demonstrate tax avoidance before invocation of TP provisions
Income Tax
Income Tax
