#Transfer Pricing
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1,377 articlesIncome Tax
Income Tax
Outstanding receivables from international transactions held to be within the jurisdiction of TPO
Income Tax
Income Tax
Transfer Pricing – Reimbursement of incentive paid to employees through Indian co.
Income Tax
Income Tax
Transfer Pricing – Super-normal profit cos must be excluded from comparables. DRP must not pass cursory / laconic orders
Fema / RBI
Fema / RBI
Govt. Strategy to tackle the menace of illicit funds
Income Tax
Income Tax
Exception provided in both the provisos of s. 92C(2) with regard to the +/- 5 Percent variation applies only when more than one price is determined
Income Tax
Income Tax
If commercial transaction is at ALP, no transfer pricing addition for non-charging of interest on overdue debt can be made
Income Tax
Income Tax
Transfer pricing study of assessee and ALP of international transactions determined on the basis of such study simply cannot be rejected without any cogent reasons
Income Tax
Income Tax
It is mandatory for assessee, to follow one of prescribed methods and demonstrate that international transactions, entered into by it, with an associated enterprise, are at Arms Length Price
Income Tax
Income Tax
Pass-through costs (paid to third party vendors) not to be included in cost base for determining net profit margin
Income Tax
Income Tax
Bangalore tribunal ruling upholds transfer pricing adjustment disallowing payment of management charges
Income Tax
Income Tax
Arms’ length testing for distributors – transaction prices vis-a-vis financial results
Income Tax
Income Tax
Sale of identical goods to non-AEs cannot be taken as comparable under CUP, if there are significant differences in quantity sold, geography and cust
Income Tax
Income Tax
Arm’s length price should be based on the functional and asset profile of the company
Income Tax
Income Tax
