Search Results For: H. Srinivasulu


DCIT vs. Owens Corning Industries (India) Pvt. Ltd (ITAT Hyderabad)

COURT:
CORAM: ,
SECTION(S): ,
GENRE:
CATCH WORDS: , ,
COUNSEL:
DATE: October 13, 2014 (Date of pronouncement)
DATE: October 14, 2014 (Date of publication)
AY: 2009-10
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CITATION:
TPO cannot question commercial expediency of payment to AE. RBI approval to a transaction implies it is at arms' length price

We are of the opinion that the TPO was incorrect in going into the business expediency of payment of royalty and arriving at the conclusion of the quantum of the royalty. We find support for this proposition in the decision

DCIT vs. St. Jude Medical India Pvt. Ltd (ITAT Hyderabad)

COURT:
CORAM: ,
SECTION(S):
GENRE:
CATCH WORDS: ,
COUNSEL:
DATE: September 19, 2014 (Date of pronouncement)
DATE: October 4, 2014 (Date of publication)
AY: 2008-09
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CITATION:
Operating Profit to operating Revenue should be taken as the PLI and not Operating Profit to Operating Cost

The purpose of identifying the PLI is to ensure that the comparability of the controlled transactions is objective and reference in this regard was made by him to the OECD Transfer Pricing Guidelines 2010, wherein it was explained that the

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