ITAT: ALP quoted in different currencies held to be not comparable

Arm's length price quoted in different currencies not comparable

Jul 15, 2011

ITAT: Section 92 (pre 2002) not applicable to advertisement expenditure borne by assessee as a result of franchise agreement

Section 92 (pre 2002) not applicable to advertisement expenditure incurred in consequence of arrangement between resident assessee and Indian franchisee

Jul 15, 2011

ITAT: Internal comparables used for TP analysis not to be rejected for lack of segmental reporting

Internal comparables used for transfer pricing analysis could not be rejected for lack of segmental reporting

Jul 15, 2011

ITAT: Fundamentally separate transactions with different parties across different continents not to be clubbed for ALP computation

Various transactions carried out with different entities situated in different continents to be aggregated for TP analysis; party in respect of which reliable data for comparison is readily available should

Jul 15, 2011

ITAT: Suitable comparables to be identified after considering differences based on FAR analysis

While applying TNMM, material differences on account of FAR analysis ought to be adjusted in addition to applying turnover filter; Risk adjustment allowable where assessee was not undertaking any risk

Jul 15, 2011

HC: CBDT Instruction No.3 of 2003 held not violative of the IT Act

CBDT Instruction requiring AO to compulsorily refer cases exceeding Rs. 5 crore in value to TPO, neither arbitrary nor unreasonable

Jul 15, 2011

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