Posts

Showing posts from 2019

1.16.4.6 Question and Answer- Advance Pricing Agreements

1.16.4.5 Advance Pricing Agreements

1.16.4.4 Appeal before the High Court - Supreme Court [Sections 260A & 260B - Sections 261 & 262]

1.16.4.3 Appeal before the Income Tax Appellate Tribunal [Sections 253 & 254]

1.16.4.2 Appeal before the Commissioner of Income Tax (Appeals) – [Sections 246A, 249 & 250]

1.16.4.1 Filing of objections before the Dispute Resolution Panel [Section 144C]

1.16.3 Secondary adjustment [Section 92CE]

1.16.2 Reference to Transfer Pricing Officer [Section 92CA]

1.16.1 Power of Assessing Officer to determine ALP [Section 92C(3) & (4)]

1.15 Specific Reporting Requirements – Country by Country Reporting

1.14.5 Penalties

1.14.4 Audit Report [Section 92E]

1.14.3 Structure of Transfer Pricing Documentation

1.14.2 Information & Documents to be Kept & Maintained Us 92D (Rule 10D)

1.14.1 Documentation Requirement Under the Income-tax Act, 1961

1.13 Concept of Comparability Adjustments

1.12 Functions, Assets and Risk (‘FAR’) Analysis

1.11.13 Manner of Computation of Arm’s Length Price

1.11.12 Most Appropriate Method

1.11.11 Selection of Profit Level Indicator

1.11.10 Selection of Tested Party

1.11.9 Summary of Application of Method and its Preferences on a General Basis

1.11.8 Methods for Computing ALP [Section 92C]

1.11.7 Other Method as may be prescribed by the CBDT

1.11.6 Transactional Net Margin Method

1.11.5 Profit Split Method

1.11.4 Cost Plus Method

1.11.3 Resale Price Method

1.11.2 Comparable Uncontrolled Price Method

1.11.1 Computation of Arm’s Length Price (Section 92C)

1.10 Specified Domestic Transactions

1.9 International transaction

1.8.2 Deemed Associated Enterprises

1.8.1 Associated Enterprises

1.7 Computation of Income from Transaction with Non-Resident [Section 92]

1.5 Practical Difficulties in Application of ALP

1.4 Significance of Arm’s Length Principle

1.3 Meaning of the Term “Arm’s Length Principle”

1.2 What is Transfer Pricing

1.1 Introduction to transfer pricing