Transfer Pricing

Blog, News, Transfer Pricing

October 6, 2022

ITAT justified TP adjustment as assessee failed to prove that sum given advanced to AE was quasi-capital in nature

Case Details: Kalpataru Power Transmission … Continue reading “ITAT justified TP adjustment as assessee failed to prove that sum given advanced to AE was quasi-capital in nature”

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September 29, 2022

TPO can’t ignore certificates issued by third-party vendors of AE confirming price charged from assessee: ITAT

Case Details: Kimberly-Clark Lever (P.) … Continue reading “TPO can’t ignore certificates issued by third-party vendors of AE confirming price charged from assessee: ITAT”

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September 26, 2022

TP adjustment isn’t permitted on adhoc basis: ITAT

Case Details: HSBC Asset Management … Continue reading “TP adjustment isn’t permitted on adhoc basis: ITAT”

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September 23, 2022

TPO has to look overall business scenario to prove rendering of services by AE

Case Details: United Breweries Ltd. … Continue reading “TPO has to look overall business scenario to prove rendering of services by AE”

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September 6, 2022

TPO is required to pass order before the last date of limitation period of 60 days: ITAT

Case Details: Sigma Aldrich Chemicals … Continue reading “TPO is required to pass order before the last date of limitation period of 60 days: ITAT”

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July 7, 2022

TPO to collate data from comparable companies exercising powers u/s 133(6): ITAT

Case Details: Toyota Tsusho India … Continue reading “TPO to collate data from comparable companies exercising powers u/s 133(6): ITAT”

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July 7, 2022

CIT can’t revise order passed by AO in accordance with directions issued by DRP: ITAT

Case Details: Barclays Bank PLC … Continue reading “CIT can’t revise order passed by AO in accordance with directions issued by DRP: ITAT”

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June 30, 2022

CBDT keeps tolerance limit under Transfer Pricing for AY 2022-23 unchanged

Notification No. 70/2022, dated 28-06-2022 … Continue reading “CBDT keeps tolerance limit under Transfer Pricing for AY 2022-23 unchanged”

Blog, News, Transfer Pricing

June 30, 2022

DRP has no power to entertain rectification application filed by TPO: Mumbai ITAT

Case Details: Shapoorji Pallonji Bumi … Continue reading “DRP has no power to entertain rectification application filed by TPO: Mumbai ITAT”

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June 3, 2022

TPO can’t treat assessee as manufacturer for TP study if it was treated as trader in succeeding years: ITAT

Case Details: DCIT v. Toto … Continue reading “TPO can’t treat assessee as manufacturer for TP study if it was treated as trader in succeeding years: ITAT”