Latest Expert Exchange Queries

GST Demo Service software link: https://ims.go2customer.com
Username: demouser Password: demopass
Get your inventory and invoicing software GST Ready from Binarysoft info@binarysoft.com
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
 
 
 
 
Popular Search: ICAI offer Get Windows 7,Office 2010 in Rs.799 Taxes :: form 3cd :: ACCOUNTING STANDARD :: TAX RATES - GOODS TAXABLE @ 4% :: Central Excise rule to resale the machines to a new company :: TDS :: due date for vat payment :: list of goods taxed at 4% :: cpt :: ACCOUNTING STANDARDS :: empanelment :: articles on VAT and GST in India :: ARTICLES ON INPUT TAX CREDIT IN VAT :: VAT Audit :: VAT RATES
 
 
From the Courts »
  SRD Nutrients Private Limited vs. CCE (Supreme Court)
 Samvardhana Motherson International Ltd. (Formerly Known As(M/s Samvardhana Motherson Finance Ltd.)a Vs. Assitant Commissioner Of Income Tax, Circle 22(1) & Anr.
 Pr. Commissioner Of Income Tax (Central)-2 Vs. M/s Frontline Business Solutions Pvt. Ltd. & Ors.
 Ram Kumar Vs. Income Tax Officer, Ward-64(2) & Anr.
 Principal Commissioner Of Income Tax-8 Vs. St Microelectronics Private Ltd.
  The Chamber Of Tax Consultants vs. UOI (Delhi High Court)
 M/s Ess Distribution (Mauritius) S.N.C.Et Compagnie Vs. Assistant Commissioner Of Income Tax, Circle -1(2)(2) International Taxation, New Delhi
 Commissioner Of Income Tax (Ltu) Vs. ESPN Software India Ltd.
 Bses Rajdhani Power Ltd. Vs. Principal Commissioner Of Income Tax,
 ITO vs. Gymkhana Club (ITAT Chandigarh)
 SRD Nutrients Private Limited vs. CCE (Supreme Court)

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 2017 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