Transfer Pricing

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November 14, 2022

ITAT quashes time-barred assessment as no effort was made to forward draft order to new address intimated to AO

Case Details: DSV Solutions (P.) … Continue reading “ITAT quashes time-barred assessment as no effort was made to forward draft order to new address intimated to AO”

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November 11, 2022

Director holding no share in Company can’t be treated as Associated Enterprise: ITAT

Case Details: DCIT v. Reliance … Continue reading “Director holding no share in Company can’t be treated as Associated Enterprise: ITAT”

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October 20, 2022

DRP has 6 months to pass rectification order: Mumbai ITAT

Case Details: Michael Page International … Continue reading “DRP has 6 months to pass rectification order: Mumbai ITAT”

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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”