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between India
and United States which have implication on transfer pricing
legislation. The said Treaty either advocates application ... part
of the statutory provisions of transfer pricing by the Finance
Act of 2001. In Section
Supreme Court of India
works contract
should not be included in the `contractual transfer price'
under Section 6D as according to the learned counsel ... earth etc. should
not be included in the `contractual transfer price'. Another
minor point raised by the learned counsel
Supreme Court of India
cost through the media, that the selling prices and transfer
prices of the product would be mutually agreed from time ... tended for the appellants, that there were two
prices---'transfer price' and 'selling price' and there was
good deal
Supreme Court of India
transfer is made;
(b) (i) every dealer whose contractual transfer price during the last
year ending on or before ... such part of his
contractual transfer price as specified in Sub-sec. (2);
(ii) every dealer other than a dealer
Orissa High Court
distribution of power. The assessee has worked out the transfer price
on the basis of estimated Karnataka State Electric Board ... bill amount for the purpose of calculation of
transfer price. The learned CIT(A) found it difficult to quantify
Income Tax Appellate Tribunal - Mumbai
extent it requires compulsory reference
to Transfer Pricing Page 3584 Officer to determine arm's length
price where the aggregate ... with effect from
1.6.2002, Section 92CA titled 'Reference to Transfer Pricing Officer'.
This provision enables the Assessing Officer (AO), where
Delhi High Court
Income Tax Appellate Tribunal - Mumbai
B 4 U International Holdings Ltd. , vs Department Of Income
Income Tax Appellate Tribunal - Mumbai
Grounds of appeal relating to transfer pricing matters
On the facts and in the circumstances of the case ... learned AO/Transfer Pricing Officer ('TPO') erred in
making an addition of Rs. 4,24,78,340 to the total
Income Tax Appellate Tribunal - Bangalore
Learned CIT (A), as well Learned Assessing Officer
(AO) / Transfer Pricing Officer (TPO) have erred in law as well ... rejecting the PLI considered by the
appellant in the transfer pricing documentation maintained by it.
The Learned
Income Tax Appellate Tribunal - Delhi
issues raised in the appeal reads as under:-
(1). Transfer Pricing Issue:-
In this regard, it has been urged that ... break-up of the above addition by way
of Transfer Pricing Adjustment is as under:-
1
ITA NO. 5857
Income Tax Appellate Tribunal - Delhi
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