sitemapHome | Registration | Job Portal for CA's | Expert Exchange | Currency Converter | Post Matrimonial Ads | Post Property Ads
News shortcuts: From the Courts | News Headlines | VAT (Value Added Tax) | Placements & Empanelment | Various Acts & Rules | Latest Circulars | New Forms | Forex | Auditing | Direct Tax | Customs and Excise | ICAI | Corporate Law | Markets | Students | General | Mergers and Acquisitions | Continuing Prof. Edu. | Budget Extravaganza | Transfer Pricing | GST - Goods and Services Tax
Latest Expert Exchange
From the Courts »
 PCIT vs. Hardik Bharat Patel (Bombay High Court)
 PCIT vs. NDR Promoters Pvt. Ltd (Delhi High Court)
 Utech Developers Ltd. 305, 3rd Floor Bhanot Corner Pamposh Enclave, G.K.-I New Delhi 110 048 vs. ITO, Ward 18(1) New Delhi
 DCIT, Circle 5(1) Room No.390 C.R.building I.P.Estate New Delhi vs. BSES Yamuna Power Ltd. Shakti Kiran building Karkardoma Delhi 110 092
 DCIT, Circle 8(1) Room No.415 4th floor C.R.building I.P.Estate New Delhi 110 002 vs. Engineers India Ltd. Engineers India Bhawan 1, Bhikaji Cama Place R.K.Puram
 Sh. Gulashanobar, Sanjay Parashar, Adv., 47-A, Devika Chamber, Raj Nagar, District Centre, Ghaziabad vs. Income Tax Officer, Ward-1(2), Ghaziabad
 The DCIT, Central Circle-31, Room No.319, E-2, ARA Centre, Jhandewalan Extn. New Delhi. vs. M/s. Sutlej Agro Products Ltd., 30, Community Centre, Saket, New Delhi.
 The JCIT (TDS), 13-A, Subhash Road, Dehradun. vs. Uttaranchal Health & Family Welfare Society, SCOVA (NRHM), Sahastradhara Road, Near I.T. Park, Dehradun.
 Jindal Stainless Ltd. O.P. Jindal Marg Hisar vs. DCIT, Circle 13
 Bharat Vikas Parishad Maharana Pratap Nyas, Flat No.157, Hewo Apartments, Sector-15, Part-II, Gurgaon, Haryana. vs. The CIT (Exemptions) (Hq.), Chandigarh.
 Shri Ankit Kapoor, B-102, RG City Centre, Plot No.4, Motia Khan, Paharganj, New Delhi. vs. The Income Tax Officer, Ward-63(4), E-2 Block, Civic Centre, New Delhi.

DCIT vs. Alcatel India Limited (ITAT Delhi)
December, 05th 2014

Transfer Pricing: ALP adjustments can only be made in respect of international transactions with the AEs and cannot extend to the transactions with non AEs

It is well settled legal position that the ALP adjustments can only be made in respect of international transactions with the AEs and cannot extend to the transactions with non AEs. There are large number decisions of the coordinate benches, including in the case of Alstom Projects India Ltd Vs ACIT [26 ITR (Trib) 322], holding so. In the case of CIT Vs Stratex Networks India Pvt Ltd (354 ITR 304), Hon’ble jurisdictional High Court has also accepted this position. Learned Departmental Representative, even as vehemently relying upon the stand of the TPO, does not dispute this legal position but he contends that the factual elements embedded in this contention, at least on computation aspect, need to be verified by the TPO. That is only arithmetical part giving effect to this principle. We see no harm in this exercise.

Home | About Us | Terms and Conditions | Contact Us
Copyright 2019 CAinINDIA All Right Reserved.
Designed and Developed by Binarysoft Technologies Pvt. Ltd.
Binarysoft Technologies - Our Portfolio

Transfer Pricing | International Taxation | Business Consulting | Corporate Compliance and Consulting | Assurance and Risk Advisory | Indirect Taxes | Direct Taxes | Transaction Advisory | Regular Compliance and Reporting | Tax Assessments | International Taxation Advisory | Capital Structuring | Withholding tax advisory | Expatriate Tax Reporting | Litigation | Badges | Club Badges | Seals | Military Insignias | Emblems | Family Crest | Software Development India | Software Development Company | SEO Company | Web Application Development | MLM Software | MLM Solutions