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Articles for Tpo, search results for margin

No Adjustment If Margin Falls Within Tolerance Range Of (+/-) 5% As Per Sec 92CA: Mumbai ITAT
10 months, 2 weeks ago

No Adjustment If Margin Falls Within Tolerance Range Of (+/-) 5% As Per Sec 92CA: Mumbai ITAT

Live Law  

Finding that the margins of assessee company fell within the tolerance limit of +/-5% for AY 2005-06, the Mumbai ITAT deleted the ALP adjustments proposed by the TPO in ITEs as well as IT segments. In that case, in ITES segment margin shown by the assessee and margin which has been determined falls within the tolerance limit of +/- 5% …

Sec Bench Margin Pli Segment Itat 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
Royalty Payment For Use Of Technology Is Inextricably Linked With Manufacturing Activity: Bombay High Court
1 year, 4 months ago

Royalty Payment For Use Of Technology Is Inextricably Linked With Manufacturing Activity: Bombay High Court

Live Law  

The Bombay High Court has held that the transaction of payment of royalty for the use of technology is inextricably linked with manufacturing activity and should be aggregated with other international transactions in the manufacturing segment for the purposes of benchmarking it.The bench of Justice K.R. The Bombay High Court has held that the transaction of payment of royalty for …

International Royalty Bombay High Court Payment Tribunal Transactions Assessee