Transfer Pricing

Blog, News, Transfer Pricing

September 20, 2024

DRP Was Justified in Assuming Jurisdiction Under Sec. 154 to Rectify Its Earlier Direction | HC

Case Details: Principal Commissioner of … Continue reading “DRP Was Justified in Assuming Jurisdiction Under Sec. 154 to Rectify Its Earlier Direction | HC”

Blog, Transfer Pricing

October 17, 2024

[Analysis] UAE Corporate Tax – Navigating Intra-group Services and Transfer Pricing

The UAE Transfer Pricing (TP) … Continue reading “[Analysis] UAE Corporate Tax – Navigating Intra-group Services and Transfer Pricing”

Blog, Transfer Pricing

August 30, 2024

Understanding DEMPE Functions – Intangible Asset Allocation and Transfer Pricing Compliance

DEMPE functions refer to the … Continue reading “Understanding DEMPE Functions – Intangible Asset Allocation and Transfer Pricing Compliance”

Blog, News, Transfer Pricing

August 28, 2024

ITAT Deleted Penalty as Delay in Filing Documents with TPO Was Due to Non-Availability of Authorized Representative

Case Details: Total Energies Marketing … Continue reading “ITAT Deleted Penalty as Delay in Filing Documents with TPO Was Due to Non-Availability of Authorized Representative”

Blog, Transfer Pricing

July 16, 2024

How to use Transfer Pricing Database for Benchmarking Analysis – Step-by-Step Guide | Best Practices

A Transfer Pricing Database for … Continue reading “How to use Transfer Pricing Database for Benchmarking Analysis – Step-by-Step Guide | Best Practices”

Blog, News, Transfer Pricing

June 28, 2024

Assessment Couldn’t Be Abated if NFAC Forwarded an Assessment Order Instead of Draft Order Due to Technical Glitch

Case Details: GE Power Conversation … Continue reading “Assessment Couldn’t Be Abated if NFAC Forwarded an Assessment Order Instead of Draft Order Due to Technical Glitch”

Blog, News, Transfer Pricing

June 27, 2024

ITAT Remanded Matter as CIT(A) Dismissed All Grounds of Appeal Based on a Single Issue

Case Details: Computer Sciences Corporation … Continue reading “ITAT Remanded Matter as CIT(A) Dismissed All Grounds of Appeal Based on a Single Issue”

Blog, News, Transfer Pricing

June 18, 2024

WDV as Reflected in Books of AE Can’t Be Considered While Computing ALP of Assets Purchased From AE | HC

Case Details: PCIT v. Sarens … Continue reading “WDV as Reflected in Books of AE Can’t Be Considered While Computing ALP of Assets Purchased From AE | HC”

Blog, News, Transfer Pricing

May 7, 2024

NR Not Eligible to Approach DRP if He Was Declared as Resident by AO During Draft Assessment Proceedings

Case Details: Aldrin Alberto Araujo … Continue reading “NR Not Eligible to Approach DRP if He Was Declared as Resident by AO During Draft Assessment Proceedings”

Blog, News, Transfer Pricing

May 4, 2024

ITAT Justified Rejection of TNMM Method as TPO Considered Rates as on Invoice Date Instead of Agreement Date

Case Details: Principal Commissioner of … Continue reading “ITAT Justified Rejection of TNMM Method as TPO Considered Rates as on Invoice Date Instead of Agreement Date”