Transfer Pricing

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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

4 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

5 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

10 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

10 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

10 years ago
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