![Arm’s Length Price can’t be determined using only two Comparables: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2018/05/Arms-Length-Price-Taxscan.jpg "Arm’s Length Price can’t be determined using only two Comparables: ITAT [Read Order]")
Arm’s Length Price can’t be determined using only two Comparables: ITAT [Read Order]
In Motorola Solutions India Pvt. Ltd vs Deputy Commissioner of Income Tax, the Delhi Bench of Income Tax Appellate Tribunal (ITAT) confirming the...
![If there are Similar Transactions of Services with both Related and Unrelated Parties and Price is Comparable, It is taken to be at Arm’s Length Price: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2018/04/Arms-Length-Price-Taxscan.jpg "If there are Similar Transactions of Services with both Related and Unrelated Parties and Price is Comparable, It is taken to be at Arm’s Length Price: ITAT [Read Order]")
![ITAT Invalidates Addition made by way of Adjustment to ALP in respect of Transaction of Providing Guarantee to AE [Read Order]](https://www.taxscan.in/wp-content/uploads/2016/09/ITAT-Chandigarh-Taxscan.jpg "ITAT Invalidates Addition made by way of Adjustment to ALP in respect of Transaction of Providing Guarantee to AE [Read Order]")
![Purchase of Shares of AE can’t be regarded as International Transaction and Investigation u/s 92 cannot Applicable: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2016/07/Shares-TaxScan.jpg "Purchase of Shares of AE can’t be regarded as International Transaction and Investigation u/s 92 cannot Applicable: ITAT [Read Order]")
Brand Promotion Expenses incurred by BMW India constitute ‘International Transaction’: ITAT [Read Order]
Advertising, marketing and promotional expenses incurred by BMW India for the brand promotion of BMW Gropu would constitute ‘international transaction’ within the meaning of section 92 of the Income...
![Brand Promotion Expenses incurred by BMW India constitute ‘International Transaction’: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2017/11/BMW-India-Taxscan.jpg "Brand Promotion Expenses incurred by BMW India constitute ‘International Transaction’: ITAT [Read Order]")
Delhi HC Upholds Clubbing of Two distinct Revenue Streams for ALP purpose: Grants Relief to ESPN [Read Order]
While granting relief to ESPN Software India Ltd, a division bench of the Delhi High Court upheld the ITAT ruling wherein two distinct revenue streams i.e. sale of air time with distribution business,...
![Delhi HC Upholds Clubbing of Two distinct Revenue Streams for ALP purpose: Grants Relief to ESPN [Read Order]](https://www.taxscan.in/wp-content/uploads/2017/11/ESPN-Taxscan.jpg "Delhi HC Upholds Clubbing of Two distinct Revenue Streams for ALP purpose: Grants Relief to ESPN [Read Order]")
No Penalty If ALP was determined as per section 92C in Good Faith and with Due Diligence: ITAT Delhi [Read Order]
A division bench of the Delhi ITAT, last week held that penalty under section 271(1)(c ) of the Income Tax Act, 1961 cannot be levied if the Arm’s Length Price (ALP) was determined as per the scheme...
![No Penalty If ALP was determined as per section 92C in Good Faith and with Due Diligence: ITAT Delhi [Read Order]](https://www.taxscan.in/wp-content/uploads/2016/12/No-Penalty-Taxscan.jpg "No Penalty If ALP was determined as per section 92C in Good Faith and with Due Diligence: ITAT Delhi [Read Order]")
![CBDT notifies Transfer Pricing Tolerance Limit for AYs 2017-18 and 2018-19 [Read Notification]](https://www.taxscan.in/wp-content/uploads/2017/06/Transfer-Pricing.jpg "CBDT notifies Transfer Pricing Tolerance Limit for AYs 2017-18 and 2018-19 [Read Notification]")
Royalty & Technical Assistance Fee are two separate Transactions for the purpose of computing ALP: Delhi HC [Read Judgment]
While upholding the order of ITAT, the division bench of the Delhi High Court held that royalty and technical assistance fee did not form part of a composite transaction and have to be treated as two...
![Royalty & Technical Assistance Fee are two separate Transactions for the purpose of computing ALP: Delhi HC [Read Judgment]](https://www.taxscan.in/wp-content/uploads/2016/06/Delhi-High-Court-2-Tax-Scan.jpg "Royalty & Technical Assistance Fee are two separate Transactions for the purpose of computing ALP: Delhi HC [Read Judgment]")
Transaction of extending Credit Period to AEs can be regarded as 'International Transaction' for the purpose of determining ALP: ITAT Bangalore [Read Order]
The Bangalore bench of Income Tax Appellate Tribunal recently ruled that transaction of extending credit period to Associate Enterprises can be regarded as “international transaction” for the purpose...
