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Articles for Tpo, search results for income

ITAT Half Yearly Digest: January To June 2024 - PART I
5 months, 2 weeks ago

ITAT Half Yearly Digest: January To June 2024 - PART I

Live Law  

S. 54F Exemption Not Available On Property Predominantly Being Used For Religious Purposes: ITAT Case Title: Asstt. Explanation 3 To Sec 147 Can't Be Resorted To Make Addition On Any Other Issue Which Is Not Included In Reasons For Reopening: New Delhi ITAT Case Title: Vishram Sahakari Awas Samiti Limited verses ITO On finding that no addition is made based …

India Delhi Kolkata Tax Indian Income Tax Title
Final Assessment Made By AO After Expiry Of One Month Of Receiving Directions From Dispute Resolution Panel, Is Time Barred: Chennai ITAT
7 months ago

Final Assessment Made By AO After Expiry Of One Month Of Receiving Directions From Dispute Resolution Panel, Is Time Barred: Chennai ITAT

Live Law  

The Chennai ITAT recently held that the final assessment order dated Nov 21, 2017 passed after expiry of one month from the end of the month in which the DRP directions were received by the Revenue is barred by limitation and hence, “passed wholly without jurisdiction and therefore, null in the eyes of law”. Section 144C of Income tax Act …

Assessment Order Month Department Bench Final One Month
AO Is Not Clothed With Powers To Ascertain ALP Of Any International Transaction: Delhi High Court
8 months, 2 weeks ago

AO Is Not Clothed With Powers To Ascertain ALP Of Any International Transaction: Delhi High Court

Live Law  

The Delhi High Court has held that AO is not clothed with the powers to ascertain the Arm's Length Price of any international transaction.The bench of Justice Yashwant Varma and Justice Purushaindra Kumar Kaurav has observed that the AO is not clothed with the powers to ascertain the ALP of any international transaction that is selected based on the transfer …

International Court Transfer Delhi High Court Order Income Pricing
ITAT Dirests ALP Computation Towards Guarantee Commission @ 0.3523% In Case Of Macrotech Developers
1 year, 1 month ago

ITAT Dirests ALP Computation Towards Guarantee Commission @ 0.3523% In Case Of Macrotech Developers

Live Law  

The Mumbai Bench of Income Tax Appellate Tribunal has directed the ALP Computation Towards Guarantee Commission at a rate of 0.3523% in the case of Macrotech Developers.The bench of Kuldip Singh and Padmavathy S. has observed that the rate of guarantee commission is required to be determined on the basis of the credit rating of the issuer company. The Mumbai …

Case Commission Rate Given Itat Guarantee Assessee
Delhi High Court Upholds ITAT’s Decision On Selection Of Comparables For Determination Of Arm’s Length Price Of An International Transaction
1 year, 1 month ago

Delhi High Court Upholds ITAT’s Decision On Selection Of Comparables For Determination Of Arm’s Length Price Of An International Transaction

Live Law  

The Delhi High Court had upheld the decision of the Income Tax Appellate Tribunal on the selection of comparables for the determination of the arm’s length price of an international transaction.The Bench of Justice Rajiv Shakdher and Justice Girish Kathpalia observed that the Tribunal not only followed the previous orders mentioned above to maintain consistency but also examined. The Delhi …

High Court Order Price Tribunal Transaction Itat Assessee
ALP Of The ESOP Expenses Cannot Be Taken As ‘Nil’: ITAT
1 year, 2 months ago

ALP Of The ESOP Expenses Cannot Be Taken As ‘Nil’: ITAT

Live Law  

The Mumbai Bench of Income Tax Appellate Tribunal has held that the arm's-length price of the employee stock option plan expenses cannot be taken as ‘Nil’.The bench of Rahul Chaudhary and S. Rifaur Rahman has observed that the transfer pricing addition of INR 26,53,078 is, therefore, set aside, and the TPO/Assessing Officer is. The Mumbai Bench of Income Tax Appellate …

Expenses Employee Inr Itat Appellant Esop Tpo
TNMM Should Be Applied In Respect Of International Transaction Of `Sale Of Finished Goods’: ITAT
1 year, 3 months ago

TNMM Should Be Applied In Respect Of International Transaction Of `Sale Of Finished Goods’: ITAT

Live Law  

The Pune bench of the Income Tax Appellate Tribunal has held that the Transactional Net Margin Method should be applied in respect of international transactions of `Sale of finished goods’.The bench of R.S. The Pune bench of the Income Tax Appellate Tribunal has held that the Transactional Net Margin Method should be applied in respect of international transactions of `Sale …

International Sale Method Huge Transaction Applied Tnm
Assessing Officer Cannot Apply Wrong Method In Absence Of Audited Financials Of AE: Delhi ITAT
2 years, 7 months ago

Assessing Officer Cannot Apply Wrong Method In Absence Of Audited Financials Of AE: Delhi ITAT

Live Law  

The Delhi Bench of the Income Tax Appellate Tribunal consisting of Yogesh Kumar and Dr. B.R.R. Subsequently, a draft assessment order under section 143 read with section 144C of the Income Tax Act was passed, proposing Transfer Pricing Adjustment on the basis of TPO's order. An assessment order was passed under section 143 read with section 144C of the Income …

Tax Assessment Order Income Financials Tribunal Act
TPO To Mandatorily Pass Order Determining Arm's Length Pricing Within 60 Days: Madras High Court
2 years, 8 months ago

TPO To Mandatorily Pass Order Determining Arm's Length Pricing Within 60 Days: Madras High Court

Live Law  

The Madras High Court bench of Justice R.Mahadevan and Justice J.Sathya Narayan Prasad has held that the transfer pricing officer must mandatorily pass the order determining arm's length pricing within 60 days. The Deputy Commissioner of Income Tax passed the order under Section 92CA of the Income Tax Act, which, according to the assessee, was passed, after the time limit …

Tax Assessment Income Tax Order Income Pricing Pass