Tag Archives: GE India Industrial (P.) Ltd.

TP adjustments must be restricted to AE transactions and routine corporate expenses excluded. Issue Whether transfer pricing adjustments must be restricted solely to international transactions with Associated Enterprises (AEs) or extended entity-wide. Whether non-recurring or non-AE expenses (amortization of goodwill, bad debts, legal costs) should be excluded from operating costs under TNMM. Whether the TPO… Read More »

Transfer pricing adjustments apply strictly to AE transactions, requiring fresh verification of turnover and operating cost filters. Issue Whether transfer pricing adjustments under Chapter X must be restricted solely to international transactions with Associated Enterprises (AEs) rather than entity-level operations. Whether arbitrary application of a turnover filter (50% range) and exclusion/inclusion of non-recurring operating costs,… Read More »