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| 2012 | |
| TP/10/2012 | Interest free loan granted is required to comply with arm’s length principle and domestic interest rates cannot be used as comparable to a foreign currency loan transaction |
| TP/09/2012 | Arm’s length price determined under the Transfer Pricing regulations cannot be applied to compute “Ordinary Profits” to fetter profits eligible for claiming tax holiday. |
| TP/08/2012 | Investment advisory services should not be compared with Merchant banking business and comparable selected by taxpayer cannot be rejected by tax authorities without providing cogent reasons |
| TP/07/2012 | Payment of brand fees cannot be disallowed only on the grounds of continous losses |
| TP/06/2012 | Intra group mergers or amalgamations exempted and simplification in procedure under the Combination Regulations |
| TP/05/2012 | The Chennai Tribunal have held that penalty under section 271G of the Income-tax Act, 1961 [“the Act”] cannot be levied for benign reasons in the nature of procedural issues provided the taxpayer has maintained substantial documentation in support of its arm’s length price. |
| TP/04/2012 | Robust FAR analysis and industry dynamics play a key role in substantiating Taxpayer’s position |
| TP/03/2012 | TPO not bound to disclose the entire process followed for collection of information u/s 133(6); Taxpayer entitled to cross-examine the parties; TPO to take into consideration contemporaneous data that becomes available after the ‘specified date’ |
| TP/02/2012 | Adjustments to be restricted only to international transactions and TP adjustment cannot form the basis for rejecting the books of accounts of the taxpayer |
| TP/01/2012 | Application of controlled transaction in specific circumstances has been upheld |