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Transfer Pricing alerts

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Deloitte's continuous alerts keep you updated with the latest that's happening. Watch this space regularly.

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

 

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