Tag Archives: ARMS LENGTH PRICE

Arm’s length price for Assessment Year 2016-2017

THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)] MINISTRY OF FINANCE (Department of Revenue) NOTIFICATION New Delhi, the 14th July, 2016 [INCOME TAX] S. O. 2425(E).—In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act,1961 (43 of 1961), read with proviso to sub-rule (7)… Read More »

Companies having related party transactions above 15% of turnover could not be chosen as comparables

Whether in case of assessee, rendering software development services to its AE, companies developing their own software products could not be accepted as comparables while determining ALP  Held, yes Whether where turnover of assessee-company was Rs. 20.88 crores, companies having turnover in excess of Rs. 200 crores could not be accepted as comparables Held, yes… Read More »

COMPUTATION OF ALP ACCEPTANCE OF VODAFONE INDIA CASE

SECTION 92C OF THE INCOME-TAX ACT, 1961 – TRANSFER PRICING – COMPUTATION OF ARM’S LENGTH PRICE (ALP) – ACCEPTANCE OF ORDER OF HIGH COURT OF BOMBAY IN CASE OF VODAFONE INDIA SERVICES PVT. LTD. [2014] 50 TAXMANN.COM 300 (BOMBAY) INSTRUCTION NO. 2/2015 [F.NO.500/15/2014-APA-I], DATED 29-1-2015 In reference to the above cited subject, I am directed… Read More »