Transfer Pricing
Transfer Pricing Entities Operating On Economic Upscale Can’t Be Included As Comparables Of Those Working On Cost Plus Pricing: Delhi High Court
The Delhi High Court has held that Transfer Pricing Entities operating on economic upscale cannot be included as comparables of those working on cost...
Uncontrolled Entities As Comparables For Determining ALP; Delhi High Court Remands Back Matter To ITAT
The Delhi High Court remanded the matter to Income Tax Appellate Tribunal (ITAT) in an appeal challenging uncontrolled entities as comparables for determining ALP...
PE Is An Independent Taxable Entity, Affirms Delhi High Court
The Delhi High Court has held that a Permanent Establishment (PE) is conceived to be an independent taxable entity and cannot possibly be doubted...
Delhi High Court Upholds ITAT’s Order Allowing Customs-Duty Adjustment On Import Of Watches
The Delhi High Court while dismissing the appeal of the income tax department upheld the order passed by the Income Tax Appellate Tribunal (ITAT)...
Nature Of Trading Business Can’t Be Foundation To Conclude Principal-Agent Relationship Under Indo-Japan Tax Treaty: ITAT
The Income Tax Appellate Tribunal Delhi, observed that the nature of trading business can't be the foundation to conclude principal-agent relationship under Indo-Japan Tax...
Impermissible For TPO To Doubt Commercial Soundness Of Expenditure That May Be Incurred: Delhi High Court
The Delhi High Court ruled that it is impermissible for Transfer Pricing Officer to doubt commercial soundness of expenditure that may be incurred.
The bench...
Whether International Transactions With Non-Korean AEs Similar To MAP Covered Korean AE: ITAT Remit Back TP Adjustment To TPO
The Income Tax Appellate Tribunal, Chennai, remitted back the Transfer Pricing adjustment to Transfer Pricing Officer while stating that whether international transactions with Non-Korean...
ALP On Account Of Corporate Guarantee At 0.50% On Guaranteed Amount Is Proper Commission: ITAT
The Income Tax Appellate Tribunal (ITAT), Hyderabad Bench direct the Assessing Officer/learned TPO to adopt the same at 0.50% on the guaranteed amount.
The corporate...