![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]")
ITAT directs to Recompute ALP by including the Excluded Comparable Chosen for Transfer Pricing [Read Order]
The two member bench of Delhi Income Tax Appellate Tribunal ( ITAT ) comprising Amit Shukla ( Judicial Member ) and Padmavathy S. ( Accountant Member...
![Functional Dissimilarity between Companies and Assessee: Delhi HC upholds Order of ITAT Directing Exclusion of Comparables [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/01/Functional-Dissimilarity-Companies-Assessee-Delhi-HC-ITAT-Exclusion-of-Comparables-taxscan.jpg "Functional Dissimilarity between Companies and Assessee: Delhi HC upholds Order of ITAT Directing Exclusion of Comparables [Read Order]")
![No Material basis for Discrediting Debit Notes: Delhi HC upholds ITAT order on deletion of Disallowance of Engineering Fees [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/No-Material-Basis-Discrediting-Debit-Notes-Delhi-HC-ITAT-Deletion-of-Disallowance-Engineering-Fees-taxscan.jpg "No Material basis for Discrediting Debit Notes: Delhi HC upholds ITAT order on deletion of Disallowance of Engineering Fees [Read Order]")
![AMP Expenses incurred not Amounts to International Transaction: Delhi HC upholds ITATs order [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/AMP-Expenses-Incurred-Amounts-to-International-Transaction-Delhi-HC-ITATS-Order-TAXSCAN.jpg "AMP Expenses incurred not Amounts to International Transaction: Delhi HC upholds ITATs order [Read Order]")
TNMM is Most Appropriate Method in absence of details of independent contracts/functions/ services rendered to different AEs and unrelated parties: ITAT [Read Order]
The Delhi bench of the Income Tax Appellate Tribunal (ITAT) held that the transactional net margin method (TNMM) is the most appropriate method in the absence of details of independent...
![TNMM is Most Appropriate Method in absence of details of independent contracts/functions/ services rendered to different AEs and unrelated parties: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/10/TNMM-Most-Appropriate-Method-TNMM-is-Most-Appropriate-Method-in-absence-of-details-of-independent-contracts-ITAT-taxscan.jpg "TNMM is Most Appropriate Method in absence of details of independent contracts/functions/ services rendered to different AEs and unrelated parties: ITAT [Read Order]")
Issuance of DIN number is Insignificant and Superfluous, when it is not mentioned on the Body of Communication: ITAT [Read Order]
The Delhi Bench of Income Tax Appellate Tribunal (ITAT) held that simultaneous issue of the DIN number is insignificant and superfluous exercise, in the absence of mentioning the DIN number on the...
![Issuance of DIN number is Insignificant and Superfluous, when it is not mentioned on the Body of Communication: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/10/issuance-DIN-insignificant-communication-ITAT-director-identification-number-din-number.jpg "Issuance of DIN number is Insignificant and Superfluous, when it is not mentioned on the Body of Communication: ITAT [Read Order]")
Qualifying Activities under TTS is outside provisions of TP: ITAT deletes addition on account of allocation of Head Office Expenses [Read Order]
The Income Tax Appellate Tribunal (ITAT) Mumbai bench while deleting additions made towards the allocation of head office expenses held that qualifying activities under Tonnage Tax Scheme (TTS) are...
![Qualifying Activities under TTS is outside provisions of TP: ITAT deletes addition on account of allocation of Head Office Expenses [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/10/Qualifying-Activities-TTS-outside-provisions-TP-ITAT-addition-allocation-Head-Office-Expenses-taxscan.jpg "Qualifying Activities under TTS is outside provisions of TP: ITAT deletes addition on account of allocation of Head Office Expenses [Read Order]")
Absence of Express Agreement for Brand Promotion Excludes AMP Expenditure as International Transaction: ITAT deletes Addition on Kellogg India
The Mumbai bench of the Income Tax Appellate Tribunal (ITAT) held that the transactions in question would not constitute international transaction relating to AMP expenditure. The Assessee...
Benefit of ALP falls within Tolerance Band of +/- of 5% as per Section 92C(2) of Income Tax Act: ITAT [Read Order]
The Delhi bench of the Income Tax Appellate Tribunal (ITAT) held that the benefit of Arm's Length Price (ALP) falls within the tolerance band of +/- of 5% as per Section 92C(2) of the Income Tax Act,...
![Benefit of ALP falls within Tolerance Band of +/- of 5% as per Section 92C(2) of Income Tax Act: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Arms-Length-Price-Benefit-ALP-falls-Tolerance-Band-Income-Tax-Act-ITAT-taxscan.jpg "Benefit of ALP falls within Tolerance Band of +/- of 5% as per Section 92C(2) of Income Tax Act: ITAT [Read Order]")
Transfer Pricing Adjustment shall not be made on account of Intra-Group Services available from AE for Manufacturing & Trading Services, if proven with Documentary Evidences: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT) Mumbai bench held that transfer pricing adjustment should not be made on account of Intra -Group Services available from Associate Enterprise (AE)...
![Transfer Pricing Adjustment shall not be made on account of Intra-Group Services available from AE for Manufacturing & Trading Services, if proven with Documentary Evidences: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/Transfer-Pricing-Adjustment-Transfer-Pricing-Adjustment-Transfer-Pricing-Adjustment-shall-not-be-made-on-account-of-Intra-Group-Services-Intra-Group-Services-AE-taxscan.jpg "Transfer Pricing Adjustment shall not be made on account of Intra-Group Services available from AE for Manufacturing & Trading Services, if proven with Documentary Evidences: ITAT [Read Order]")
ITAT directs Re-adjudication on Transfer Pricing Adjustments against Reckitt Benckiser by Treating allocated Expenses as NIL [Read Order]
The Kolkata bench of the Income Tax Appellate tribunal held that as no method has been applied by the TPO or DRP to bench-mark these transactions, the issue be remitted back to TPO. ...
![ITAT directs Re-adjudication on Transfer Pricing Adjustments against Reckitt Benckiser by Treating allocated Expenses as NIL [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/ITAT-Re-adjudication-Transfer-Pricing-Adjustments-Reckitt-Benckiser-taxscan.jpg "ITAT directs Re-adjudication on Transfer Pricing Adjustments against Reckitt Benckiser by Treating allocated Expenses as NIL [Read Order]")