Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
DISPUTED TELEPHONE PAYMENT – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
PENALTY UNDER SECTION 271(1)(C) IN CASE OF ADDITIONS AS PER MAP RESOLUTION
Section 271(1)(c) provides that the AO or CIT(A) may levy a penalty where the assessee has concealed the particulars of his income or has furnished inaccurate particulars of his income. The Karnataka HC dealt with a situation as to whether penalty u/s 271(1)(c) can be levied where the addition is made as per MAP resolution […]
PENALTY UNDER SECTION 271(1)(c) IN CASE OF TP ADJUSTMENT
Section 271(1)(c) inter alia provides that the AO or CIT(A) may levy a penalty where the taxpayer has concealed the particulars of his income or has furnished inaccurate particulars of his income. Explanation 7 to s 271 provides that where transfer pricing addition is made under s 92C(4), the amount so added or disallowed […]
DIVIDEND INCOME – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]