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DATE: November 28, 2014 (Date of pronouncement)
DATE: December 3, 2014 (Date of publication)
AY: 2004-05
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CITATION:
Transfer Pricing: Comparables with more than 25% RPTs have to be excluded. There are no fetters on the assessee's right to claim that a comparable included by him should be excluded

(i) The principal question about the exclusion of companies with more than 25% RPTs from the list of comparables on account of these becoming controlled transactions, has been fairly decided by various benches of the Tribunal. It has been held …

ACIT vs. Convergys India Service (P) Ltd (ITAT Delhi) Read More »

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DATE: November 17, 2014 (Date of pronouncement)
DATE: November 19, 2014 (Date of publication)
AY: 2006-07
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CITATION:
CUP method can be applied by a comparing a pricing formulae, rather than the pricing quantification in amount. Rule 10AB inserted w.e.f. 01.04.2012 is beneficial in nature and so retrospective w.e.f. 01.04.2002

The assessee followed the 50:50 business model of sharing residual profits in equal ratio with the service provider at the other end of the transaction i.e. at the consignee’s end in the case of export transaction and at consigner’s end …

Toll Global Forwarding India Pvt Ltd vs. DCIT (ITAT Delhi) Read More »