Comparables

Profit Level Indicator – All Related transactions cannot be considered for determining ALP

CLR Editorial Notes: In this particular case, the assessee™s parent company, Digital Microwave Corporation USA, had supplied an equipment to its Indian customers for which the assessee received a decided commission. The equipment was covered by warranty and the service relating to its installation and  annual maintenance was provided by the assessee in India. It is annual… Read More

Tags: Australian Labor PartyCITCommonwealth Law ReportsComparablesIndiaTPOtransfer pricingUnited States

Foreign Associate Enterprise cannot be the tested party & Transfer pricing can exceed overall group profits

CLR Editorial Notes: The Tribunal had to consider the following important transfer pricing issues in this case: (i) whether the foreign Associated Enterprise can be taken as as the tested party & if the sale price received by the foreign AEs from the services ultimately sold to customers is equal to that charged by the… Read More

Tags: Arm's length principleComparablesIndiatransfer pricing

Turnover filter & comparisons – Important principles explained

CLR Editorial Notes: The Tribunal had to consider the following important transfer pricing issues: (i) whether a one-time and extraordinary item of expenditure (ESOP cost) debited to the assessee™s P&L A/c has to be excluded while comparing the margins, (ii) whether for the purpose of comparison of margins, the consolidated results of comparables having profit… Read More

Tags: American ExpressComparablesInfosysOECDPuneTPOtransfer pricing

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