Infosys & TCS Subsidiaries not ‘Comparables’ for ALP Determination in A.Y. 2010-11 for Cadence Design Systems: Delhi HC [Read Order]
The Delhi High Court in a recent Income Tax Appeal directed the exclusion of Tata Consultancy Services ( TCS ) E-Serve International Ltd., TCS...
![ALP Adjustment not permissible on Notional Amount of Royalty Paid by Overseas Subsidiary: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/05/ALP-Adjustment-Notional-Amount-Royalty-Paid-Overseas-Subsidiary-ITAT-taxscan.jpg "ALP Adjustment not permissible on Notional Amount of Royalty Paid by Overseas Subsidiary: ITAT [Read Order]")
![ITAT directs to Recompute ALP by including the Excluded Comparable Chosen for Transfer Pricing [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/02/Income-Tax-ITAT-ITAT-Delhi-Arm-Length-Price-transfer-pricing-Comparable-companies-TAXSCAN.jpg "ITAT directs to Recompute ALP by including the Excluded Comparable Chosen for Transfer Pricing [Read Order]")
Delhi HC upholds Calculation at Arm's Length of Reimbursement of AMP Expenses Incurred By Sony India On it's AE [Read Order]
In a significant case, the Delhi High Court upheld the calculation at Arm's Length of Reimbursement of advertising, marketing and promotion expenses (AMP) Expenses Incurred by Sony India on its...
![Delhi HC upholds Calculation at Arms Length of Reimbursement of AMP Expenses Incurred By Sony India On its AE [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/12/Delhi-High-Court-Sony-India-AMP-Expenses-Reimbursement-of-AMP-Expenses-advertising-promotion-expenses-Associated-Enterprises-taxscan.jpg "Delhi HC upholds Calculation at Arms Length of Reimbursement of AMP Expenses Incurred By Sony India On its AE [Read Order]")
No Weighted Average Cost of Capital method can be applied for purpose of computing ALP of Royalty income: ITAT Upholds Deletion of Adjustments in favour of Britannia Industries [Read Order]
The Kolkata bench of the Income Tax Appellate Tribunal (ITAT) upheld the deletion of adjustments in favor of Britannia Industries and held that the weighted average cost of capital (WACC) method...
![No Weighted Average Cost of Capital method can be applied for purpose of computing ALP of Royalty income: ITAT Upholds Deletion of Adjustments in favour of Britannia Industries [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/No-Weighted-Average-Cost-Average-Cost-Average-Cost-of-Capital-method-computing-ALP-ALP-Royalty-income-Royalty-ITAT-taxscan.jpg "No Weighted Average Cost of Capital method can be applied for purpose of computing ALP of Royalty income: ITAT Upholds Deletion of Adjustments in favour of Britannia Industries [Read Order]")
Rates for power made available through Indian Energy Exchange are not applicable to consumers; rather, they are rates to DISCOM: ITAT deletes TP Adjustment against Tata Steel [Read Order]
The Income Tax Appellate Tribunal (ITAT), Mumbai bench, held that rates for power made available through the Indian Energy Exchange are not applicable to consumers; instead, they are rates for...
![Rates for power made available through Indian Energy Exchange are not applicable to consumers; rather, they are rates to DISCOM: ITAT deletes TP Adjustment against Tata Steel [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/Tata-Steel-TP-Adjustment-against-Tata-Steel-income-tax-taxscan.jpg "Rates for power made available through Indian Energy Exchange are not applicable to consumers; rather, they are rates to DISCOM: ITAT deletes TP Adjustment against Tata Steel [Read Order]")
ITAT Deletes Secondary Adjustment for Upfront Discount Payment by Tech Mahindra to Secure Software and IT Services Contract with Non-Resident Venture Partner [Read Order]
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench, deleted the secondary adjustment made towards the upfront discount payment by Tech Mahindra to secure contracts for software and IT services...
![ITAT Deletes Secondary Adjustment for Upfront Discount Payment by Tech Mahindra to Secure Software and IT Services Contract with Non-Resident Venture Partner [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/ITAT-Secondary-Adjustment-Discount-Payment-Tech-Mahindra-Secure-Software-IT-Services-Contract-Non-Resident-Venture-Partner-taxscan.jpg "ITAT Deletes Secondary Adjustment for Upfront Discount Payment by Tech Mahindra to Secure Software and IT Services Contract with Non-Resident Venture Partner [Read Order]")
RPM is Most Appropriate Method for Ascertaining ALP as the Distributer did not Make any Value Addition to Goods: Delhi HC [Read Order]
The Delhi High Court Resale Price Method (RPM) is the Most Appropriate Method(MOM) for Ascertaining Arm’s Length Price (ALP) as the distributor did not make any value addition to the goods. The...
TNMM is Suitable Method for Determining ALP for International Transactions Concerning Indenting-Transactions: Delhi HC dismisses Appeal [Read Order]
The Delhi High Court dismissed appeal and observed that Transaction Net Margin Method (TNMM) is suitable method for determining Arm’s Length Price (ALP) for international transactions concerning...
![TNMM is Suitable Method for Determining ALP for International Transactions Concerning Indenting-Transactions: Delhi HC dismisses Appeal [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/07/TNMM-TNMM-is-Suitable-Method-for-Determining-ALP-for-International-Transactions-ALP-International-Transactions-Indenting-Transactions-Delhi-High-Court-Taxscan.jpg "TNMM is Suitable Method for Determining ALP for International Transactions Concerning Indenting-Transactions: Delhi HC dismisses Appeal [Read Order]")