Search Results For: aggregation


Cummins India Limited vs. ACIT (ITAT Pune)

COURT:
CORAM: ,
SECTION(S): ,
GENRE:
CATCH WORDS: , ,
COUNSEL:
DATE: December 31, 2014 (Date of pronouncement)
DATE: January 8, 2015 (Date of publication)
AY: 2005-06
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CITATION:
Transfer Pricing: Closely linked international transactions can be aggregated to determine the ALP

On a combined reading of Rule 10A(d) and 10B of the Rules, a number of transactions can be aggregated and construed as a single ‘transaction’ for the purposes of determining the ALP, provided of course that such transactions are ‘closely linked’

Toyota Kirloskar Auto Parts Pvt. Ltd vs. ACIT (ITAT Bangalore)

COURT:
CORAM: ,
SECTION(S):
GENRE:
CATCH WORDS: , ,
COUNSEL:
DATE: November 21, 2014 (Date of pronouncement)
DATE: December 3, 2014 (Date of publication)
AY: 2008-09
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CITATION:
Transfer Pricing: Law on aggregation of several international transactions to determine the Arms' Length Price explained

1) Whether the payment of royalty is interlinked and interconnected with the other international transactions of the assessee with its AE’s? 2) Where different international transactions with the AE are interconnected and interlinked, whether the aggregation of the transactions is

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