Transfer Pricing

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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”

Blog, News, Transfer Pricing

April 19, 2024

No Need for a Registered/Notarized Agreement for Undertaking International Transactions With Group Cos | ITAT

Case Details: CRM Services India … Continue reading “No Need for a Registered/Notarized Agreement for Undertaking International Transactions With Group Cos | ITAT”

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February 16, 2024

No Legal Bar in Selecting Foreign AE as Tested Party for Determining ALP | HC

Case Details: PCIT v. ITC … Continue reading “No Legal Bar in Selecting Foreign AE as Tested Party for Determining ALP | HC”

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January 9, 2024

[Opinion] All About Form 3CEB by Non-Residents

CA Mohit Manav Sharma & … Continue reading “[Opinion] All About Form 3CEB by Non-Residents”

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January 5, 2024

[Opinion] All about Safe Harbour Rule

CA Mohit Manav Sharma & … Continue reading “[Opinion] All about Safe Harbour Rule”

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December 14, 2023

ALP of Intra-group Services Cannot be Considered Nil If Services Were Backed by Agreement & Evidence | ITAT

Case Details: Pall India (P.) … Continue reading “ALP of Intra-group Services Cannot be Considered Nil If Services Were Backed by Agreement & Evidence | ITAT”

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December 4, 2023

No TP Adjustment If Providing Performance Guarantee or Corporate Guarantee Did Not Give Any Benefit to AE | ITAT

Case Details: Afcons Infrastructure Ltd. … Continue reading “No TP Adjustment If Providing Performance Guarantee or Corporate Guarantee Did Not Give Any Benefit to AE | ITAT”

Blog, Transfer Pricing

October 21, 2023

Important Judicial Rulings in Transfer Pricing | 2023

Table of Contents Whether selection … Continue reading “Important Judicial Rulings in Transfer Pricing | 2023”

Blog, News, Transfer Pricing

October 11, 2023

No Transfer Pricing Adjustment if Interest Cost was Negligible in Comparison to Benefit Derived by Assessee from AE

Case Details: Rubamim Ltd. v. … Continue reading “No Transfer Pricing Adjustment if Interest Cost was Negligible in Comparison to Benefit Derived by Assessee from AE”