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Co. engaged in manufacturing of pace maker is comparable to co. engaged in manufacturing of laboratory equipments

October 31, 2018[2018] 98 312 (Bangalore - Trib.)

IT/ILT : Company engaged in manufacture and trading of pace maker could be compared with assessee manufacture of laboratory and processing equipments

IT/ILT : TPO should apply principle of treating foreign exchange fluctuation as operating in nature under both situations, when there is a loss as well as when there is a gain and same principle is to be applied to determine profit margins of assessee and comparable companies

IT/ILT : Indian transfer pricing regulations refer to adjustments on uncontrolled transactions, however same has to be read with rule 10B(3) which clearly emphasizes necessity and compulsion of undertaking adjustments and, hence, in case appropriate adjustments cannot be made to uncontrolled transaction, due to lack of data, then in order to read provisions of transfer pricing regulations in harmony, adjustments should be made on tested party

IT/ILT : Transfer pricing adjustment should be restricted only to AE related transactions of assessee

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