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Articles for Tpo, search results for price

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
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
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