Transfer Pricing

Blog, News, Transfer Pricing

May 15, 2023

Supreme Court Remands Transfer Pricing Issue Back to High Court, Citing Observations from SAP Labs Ruling

Case Details: PCIT v. Subex … Continue reading “Supreme Court Remands Transfer Pricing Issue Back to High Court, Citing Observations from SAP Labs Ruling”

Blog, News, Transfer Pricing

May 11, 2023

Transfer Pricing in Mergers & Acquisitions – Strategies for Ensuring Compliance & Maximizing Value

CA Pawan Singh – [2023] … Continue reading “Transfer Pricing in Mergers & Acquisitions – Strategies for Ensuring Compliance & Maximizing Value”

Blog, News, Transfer Pricing

May 6, 2023

Examining Validity of Rectificatory Jurisdiction by DRP in Shapoorji Pallonji Case

Dr. Ajit Kumar Singh – … Continue reading “Examining Validity of Rectificatory Jurisdiction by DRP in Shapoorji Pallonji Case”

News, Blog, Transfer Pricing

April 26, 2023

[Opinion] HC to Address ‘Substantial Question of Law’ on Comparable Selection & ALP Determination

CA Mithilesh Reddy & CA … Continue reading “[Opinion] HC to Address ‘Substantial Question of Law’ on Comparable Selection & ALP Determination”

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April 21, 2023

Arms Length Price (ALP) determined by ITAT can be Subject to Scrutiny: SC

Case Details: Sap Labs India … Continue reading “Arms Length Price (ALP) determined by ITAT can be Subject to Scrutiny: SC”

Blog, News, Transfer Pricing

March 24, 2023

Jurisdictional Issue can be raised in ITAT Miscellaneous Petition despite HC involvement: ITAT

Case Details: YCH Logistics (India) … Continue reading “Jurisdictional Issue can be raised in ITAT Miscellaneous Petition despite HC involvement: ITAT”

Blog, News, Transfer Pricing

March 23, 2023

TPO couldn’t allocate entire ‘market spread’ to assessee’s without FAR of AE at trading location: ITAT

Case Details: UBS AG v. … Continue reading “TPO couldn’t allocate entire ‘market spread’ to assessee’s without FAR of AE at trading location: ITAT”

Blog, News, Transfer Pricing

November 14, 2022

ITAT quashes time-barred assessment as no effort was made to forward draft order to new address intimated to AO

Case Details: DSV Solutions (P.) … Continue reading “ITAT quashes time-barred assessment as no effort was made to forward draft order to new address intimated to AO”

Blog, News, Transfer Pricing

November 11, 2022

Director holding no share in Company can’t be treated as Associated Enterprise: ITAT

Case Details: DCIT v. Reliance … Continue reading “Director holding no share in Company can’t be treated as Associated Enterprise: ITAT”

Blog, News, Transfer Pricing

October 20, 2022

DRP has 6 months to pass rectification order: Mumbai ITAT

Case Details: Michael Page International … Continue reading “DRP has 6 months to pass rectification order: Mumbai ITAT”