Transfer Pricing

CBDT Sets 3% transaction tolerance limit & 1% for wholesale

CBDT notifies transfer pricing tolerance limit for AY 2021-22 The 35th to 65th percentile of the dataset is construed as… Read More

2 years ago

Three-tier TP Documentation & threshold Requirement

Three-tier Transfer Pricing Documentation & threshold Requirement Taxpayers are expected to maintain, on a yearly basis, a collection of detailed information… Read More

4 years ago

Bright line test can’t be applied to determine AMP Exp. ALP

The bright-line test can’t be applied to determine the ALP of AMP expenses. Honda Siel Power Products Ltd. v. DCIT, … Read More

8 years ago

Computing ALP of Distribution & AMP Expenses

SELLING EXPENSES INCURRED FOR MAKING SALES ARE DISTINCT FROM AMP EXPENSES AND, HENCE, SHOULD NOT BE INCLUDED IN THE BASE… Read More

8 years ago

Libor is Best Benchmark for Interest-Free Loan

www.carajput.com; Transfer pricing LIBOR IS THE BEST BENCHMARK UNDER TRANSFER PRICING FOR INTEREST-FREE LOANS GRANTED TO AE DCIT V. GEODESIC… Read More

8 years ago
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