CBDT notifies transfer pricing tolerance limit for AY 2021-22 The 35th to 65th percentile of the dataset is construed as the arm’s length range under the transfer pricing regulations. For cases where there are six or more comparable uncontrolled entries in the dataset and the Transactional Net Margin Method, Comparable Uncontrolled Price Method, Resale Price …
Three-tier Transfer Pricing Documentation & threshold Requirement Taxpayers are expected to maintain, on a yearly basis, a collection of detailed information and documentation relating to international transactions performed with AEs or specified domestic transactions. Rule 10D of the Income Tax Rules of 1962 provides for accurate records and documents to be kept by the taxpayer. These …
The bright-line test can’t be applied to determine the ALP of AMP expenses. Honda Siel Power Products Ltd. v. DCIT, Facts of the Case Assessee is engaged both in the manufacture of licensed products as well as the distribution of goods manufactured by its associated enterprises (AE).The assessee has entered into international transactions with its …
SELLING EXPENSES INCURRED FOR MAKING SALES ARE DISTINCT FROM AMP EXPENSES AND, HENCE, SHOULD NOT BE INCLUDED IN THE BASE AMOUNT FOR COMPUTING ALP OF AMP EXPENSES Discovery Communications India v. DCIT [Delhi ITAT], ITA No. 2931 of 2015, Date of Decision: December 04, 2015 Facts of the Case The assessee is a subsidiary of …
www.carajput.com; Transfer pricing LIBOR IS THE BEST BENCHMARK UNDER TRANSFER PRICING FOR INTEREST-FREE LOANS GRANTED TO AE DCIT V. GEODESIC LTD. [MUMBAI ITAT] ITA NO. 1656 OF 2013, DATE OF DECISION: AUGUST 12, 2015 FACTS OF THE CASE The assessee has undertaken a transaction of giving an unsecured interest-free loan to its subsidiary Geodesic Technology …