#Transfer Pricing
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1,377 articlesIncome Tax
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OECD Discussion Paper on Safe Harbour Guidelines In Transfer Pricing
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No reopening of Cases Prior to 01.04.2012 & Circular to avoid multilevel TDS on software u/s 194J -FM
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Transfer Pricing – Disallowance of excess advertisement expense by comparing with average advertisement expense of companies is an adhoc method ¬ TNMM
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TPO Cannot question business purpose of transaction
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Transfer Pricing – In Realm of evolution – Part II
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No functional incomparability if TPO not reject a comparable on same ground
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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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