Research Box
Your Session Will Expire in   seconds.
What should we do?
Reset SessionCancel Session
 
Model Commentary
As Amended upto 20th March, 2018
  • Commentry:
Search
48 Records
    • Go To Page
    • of [1 ]
INTRODUCTION
INTRODUCTION 1.1 Expressions "Transfer Price" and "Transfer Pricing" not ...
FEATURES OF THE TRANSFER PRICING REGIME UNDER CHAPTER X
FEATURES OF THE TRANSFER PRICING REGIME UNDER CHAPTER X 2.0 Features of the ...
TRANSFER PRICING PROVISIONS OF CHAPTER X - WHEN APPLICABLE TO AN ASSESSEE
TRANSFER PRICING PROVISIONS OF CHAPTER X - WHEN APPLICABLE TO AN ASSESSEE 3.1 ...
Transfer Pricing Compliances
TRANSFER PRICING COMPLIANCES 4.1 Transfer Pricing compliances required in ...
WHO ARE “ASSOCIATED ENTERPRISES” (AEs)?
WHO ARE "ASSOCIATED ENTERPRISES" (AEs)? Two or more enterprises are not AEs u/s ...
WHAT IS “INTERNATIONAL TRANSACTION”?
WHAT IS "INTERNATIONAL TRANSACTION"? 6.1 Definition of international ...
INTERNATIONAL TRANSACTIONS : PURCHASE, SALE OR LEASE OF TANGIBLE PROPERTY
INTERNATIONAL TRANSACTIONS : PURCHASE, SALE OR LEASE OF TANGIBLE PROPERTY 7.1 ...
INTERNATIONAL TRANSACTIONS : INTANGIBLE PROPERTY TRANSACTIONS
INTERNATIONAL TRANSACTIONS : INTANGIBLE PROPERTY TRANSACTIONS 8.1 Intangible ...
INTERNATIONAL TRANSACTIONS : BORROWING OR LENDING OF MONEY/ FINANCING
INTERNATIONAL TRANSACTIONS : BORROWING OR LENDING OF MONEY/ FINANCING 9.1 ...
INTERNATIONAL TRANSACTIONS : PROVISION OF SERVICES
INTERNATIONAL TRANSACTIONS : PROVISION OF SERVICES 10.1 Definition of provision ...
INTERNATIONAL TRANSACTIONS : COST CONTRIBUTION AGREEMENTS
INTERNATIONAL TRANSACTIONS : COST CONTRIBUTION AGREEMENTS 11.1 Cost ...
BUSINESS RESTRUCTURING OR ORGANISATION
BUSINESS RESTRUCTURING OR ORGANISATION 12.1 Transaction of business ...
WHAT IS ARM’s LENGTH PRICE
WHAT IS ARM's LENGTH PRICE 13.1 Rebuttable presumption that international ...
HOW TO COMPUTE ARM’S LENGTH PRICE
HOW TO COMPUTE ARM's LENGTH PRICE 14.1 Methods for determination of ALP ...
BENCHMARKING : COMPARABILITY ANALYSIS & COMPARABLES
BENCHMARKING : COMPARABILITY ANALYSIS COMPARABLES 15.1 Comparison with ...
UNDERSTANDING BUSINESS, INDUSTRY AND CONTROLLED TRANSACTION
UNDERSTANDING BUSINESS, INDUSTRY AND CONTROLLED TRANSACTION According to the ...
EXAMINATION OF COMPARABILITY FACTORS OF CONTROLLED TRANSACTION
EXAMINATION OF COMPARABILITY FACTORS OF CONTROLLED TRANSACTION Rule 10B(2) ...
TESTED PARTY
TESTED PARTY 18.1 Selection of Tested Party There is no question of selection ...
IDENTIFICATION OF 'COMPARABLES'
IDENTIFICATION OF 'COMPARABLES' 19.1 Definition of 'Comparables' Rule 10B(3) ...
DATA TO BE USED IN COMPARABILITY ANALYSIS
DATA TO BE USED IN COMPARABILITY ANALYSIS 20.1 Data to be used for analysing ...
WHAT IS COMPARABLE UNCONTROLLABLE PRICE (CUP) METHOD AND HOW TO APPLY IT TO CALCULATE ALP?
WHAT IS COMPARABLE UNCONTROLLABLE PRICE (CUP) METHOD AND HOW TO APPLY IT TO ...
WHAT IS RESALE PRICE METHOD (RPM) AND HOW TO APPLY IT TO CALCULATE ALP?
WHAT IS RESALE PRICE METHOD (RPM) AND HOW TO APPLY IT TO CALCULATE ALP? 22.1 ...
WHAT IS COST PLUS METHOD (CPM ) AND HOW TO APPLY IT TO CALCULATE ALP?
WHAT IS COST PLUS METHOD (CPM) AND HOW TO APPLY IT TO CALCULATE ALP? 23.1 Cost ...
WHAT IS PROFIT SPLIT METHOD (PSM) AND HOW TO APPLY IT TO CALCULATE ALP?
WHAT IS PROFIT SPLIT METHOD (PSM) AND HOW TO APPLY IT TO CALCULATE ALP? When ...
WHAT IS TRANSACTIONAL NET MARGIN METHOD (TNMM) AND HOW TO APPLY IT TO CALCULATE ALP?
WHAT IS TRANSACTIONAL NET MARGIN METHOD (TNMM) AND HOW TO APPLY IT TO CALCULATE ...
ANY OTHER METHOD - RULE 10AB
ANY OTHER METHOD - RULE 10AB 26.1 Rule 10AB is retrospective and effective from ...
MOST APPROPRIATE METHOD (MAM)
MOST APPROPRIATE METHOD (MAM) 27.1 Selection of MAM-factors to be taken into ...
INTERNATIONAL TRANSACTIONS : DETERMINATION OF ALP FOR IMPORT OF GOODS
INTERNATIONAL TRANSACTIONS: DETERMINATION OF ALP FOR IMPORT OF GOODS 28.1 ...
INTERNATIONAL TRANSACTIONS : DETERMINATION OF ALP FOR INTEREST FREE LOAN TO AEs
INTERNATIONAL TRANSACTIONS : DETERMINATION OF ALP FOR INTEREST FREE LOAN TO AEs ...
INTERNATIONAL TRANSACTIONS INVOLVING INTANGIBLES : DETERMINATION OF ALP
INTERNATIONAL TRAN-SACTIONS INVOLVING INTANGIBLES : DETERMINATION OF ALP 30.1 ...
INTERNATIONAL TRANSACTIONS : WHEN DEVELOPMENT CENTRES IN INDIA CAN BE TREATED AS CONTRACT R&D SERVICE PROVIDER WITH INSIGNIFICANT RISK
INTERNATIONAL TRANSACTIONS : WHEN DEVELOPMENT CENTRES IN INDIA CAN BE TREATED ...
INTERNATIONAL TRANSACTIONS : DETERMINATION OF ALP FOR INDENTING ACTIVITY
INTERNATIONAL TRANSACTIONS : DETERMINATION OF ALP FOR INDENTING ACTIVITY 32.1 ...
TRANSFER PRICING ADJUSTMENTS
TRANSFER PRICING ADJUSTMENTS 33.1 TP adjustments Transfer Pricing Adjustments ...
THIN CAPITALIZATION ADJUSTMENTS
THIN CAPITALIZATION ADJUSTMENTS 34.1 Concepts of "Thin capitalization" and ...
SECONDARY ADJUSTMENTS
SECONDARY ADJUSTMENTS 35.1 Secondary adjustments - Concept "Secondary ...
POWER OF AO TO COMPUTE ALP
POWER OF AO TO COMPUTE ALP 36.1 Power of AO to compute ALP in respect of ...
REFERENCE TO TRANSFER PRICING OFFICER - SECTION 92CA
REFERENCE TO TRANSFER PRICING OFFICER - SECTION 92CA 37.1 Power of AO to make a ...
TRANSFER PRICING DISPUTE RESOLUTION MECHANISM
TRANSFER PRICING DISPUTE RESOLUTION MECHANISM Dispute Resolution in TP cases - ...
SAFE HARBOUR RULES - SECTION 92CB
SAFE HARBOUR RULES* 39.1 "Safe harbour rules" - Concept "Safe Harbour" means ...
ADVANCE PRICING AGREEMENT - SECTIONS 92CC AND 92CD
ADVANCE PRICING AGREEMENT* 40.1 Backdrop In order to provide tax certainty and ...
OBLIGATION OF ASSESSEES TO MAINTAIN TRANSFER PRICING DOCUMENTATION - SECTION 92D
OBLIGATION OF ASSESSEES TO MAINTAIN TRANSFER PRICING DOCUMENTATION* 41.1 ...
AUDIT REPORT
AUDIT REPORT* 42.1 Obligation of assessee entering into international ...
AUDIT REPORT & DOCUMENTATION – INTERNATIONAL TRANSACTIONS
AUDIT REPORT DOCUMENTATION INTERNATIONAL TRANSACTIONS 43.1 Para 1 of Form No. ...
DUE DATE FOR FILING RETURN FOR ASSESSEES REQUIRED TO FURNISH AUDIT REPORT U/S 92E - SECTION 139
DUE DATE FOR FILING RETURN FOR ASSESSEES REQUIRED TO FURNISH AUDIT REPORT U/S ...
TIME LIMITS FOR ASSESSMENT AND REASSESSMENT - SECTIONS 153 AND 153B
TIME LIMITS FOR ASSESSMENT AND REASSESSMENT - SECTIONS 153 AND 153B 45.1 ...
DEFINITION OF SPECIFIED DOMESTIC TRANSACTIONS
DEFINITION OF SPECIFIED DOMESTIC TRANSACTIONS 46.1 Definition of specified ...
AUDIT REPORT & DOCUMENTATION – SPECIFIED DOMESTIC TRANSACTIONS
AUDIT REPORT DOCUMENTATION - SPECIFIED DOMESTIC TRANSACTIONS 47.1 Para 1 of ...
PENALTY - SECTIONS 271, 271AA, 271BA AND 271G
PENALTY - SECTIONS 271, 271AA, 271BA AND 271G 48.1 Penalty for concealment - ...