Tag Archives: National e-Assessment Centre

Transfer pricing benchmarking requires strict functional, product, and asset comparability while honoring binding administrative directives.

By | August 21, 2026

Transfer pricing benchmarking requires strict functional, product, and asset comparability while honoring binding administrative directives. Issue Whether transfer pricing adjustments, selection/exclusion of comparable entities, computation of operating margins, allocation of working capital, choice of benchmarking methods (TNMM vs. CUP vs. Berry Ratio), and disallowance of expatriate salaries can be sustained when facing functional dissimilarities, non-binding… Read More »

Concluded APA Implementation Upheld for Transfer Pricing and Disallowances Deleted Following Past Judicial Precedents

By | August 18, 2026

Concluded APA Implementation Upheld for Transfer Pricing and Disallowances Deleted Following Past Judicial Precedents Issue Whether transfer pricing adjustments under Chapter X (AMP expenses, royalty, HQ expenses, service warranty) must be recomputed in terms of a concluded Advance Pricing Agreement (APA) under Section 92CC covering the relevant assessment and rollback years. Whether disallowances of expatriate… Read More »

Reopening Barred by Limitation under Section 149 Since Corrected Escaped Income Falls Below Statutory Fifty Lakh Threshold

By | July 11, 2026

Reopening Barred by Limitation under Section 149 Since Corrected Escaped Income Falls Below Statutory Fifty Lakh Threshold Issue Whether the Assessing Officer was legally justified in issuing a reassessment notice under Section 148 beyond the normal limitation period for an alleged income escape of Rs. 70 lakhs, when a proper evaluation of the transaction records… Read More »

High Court precedent binds TPO on comparables, while healthcare and IT services are functionally distinct from market research.

By | June 19, 2026

High Court precedent binds TPO on comparables, while healthcare and IT services are functionally distinct from market research. Issue Whether the Transfer Pricing Officer (TPO) is justified in selectively applying filters and excluding historically accepted comparables despite binding High Court precedents, and whether software depreciation (60% vs 25%) and international travel expense disallowances warrant fresh… Read More »