Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net Margin Method (TNMM). The assessee selected RPM with gross profit to sales as the profit level indicator (PLI) for certain transactions, and TNMM for others. The Tax Officer rejected RPM and applied TNMM, which was upheld by the CIT(A). The key points are: The Revenue's appeal challenging the CIT(A)'s order deleting the TP adjustment was rejected, as the facts were similar to the previous year's case where the HC had ruled in the assessee's favor. The ITAT noted the Revenue failed to highlight material differences in facts between the two years that would impact the TP adjustment. The assessee's choice of method (RPM/TNMM) and tested party (foreign AE) varied between the years, but the Tax Officer applied TNMM in both years, rejecting the assessee's approach. No contentions were raised regarding the comparables. Hence, the ITAT upheld the CIT(A)'s order deleting the TP adjustment.
This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net Margin Method (TNMM). The assessee selected RPM with gross profit to sales as the profit level indicator (PLI) for certain transactions, and TNMM for others. The Tax Officer rejected RPM and applied TNMM, which was upheld by the CIT(A). The key points are: The Revenue's appeal challenging the CIT(A)'s order deleting the TP adjustment was rejected, as the facts were similar to the previous year's case where the HC had ruled in the assessee's favor. The ITAT noted the Revenue failed to highlight material differences in facts between the two years that would impact the TP adjustment. The assessee's choice of method (RPM/TNMM) and tested party (foreign AE) varied between the years, but the Tax Officer applied TNMM in both years, rejecting the assessee's approach. No contentions were raised regarding the comparables. Hence, the ITAT upheld the CIT(A)'s order deleting the TP adjustment.
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