Demystifying Secondary Adjustments

 

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Pass-Through Costs in Transfer Pricing

 

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Transfer Pricing

 

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Bacon, Lettuce and Tomato - BLT

I would like to begin by wishing all the readers a very Happy New Year and a productive 2016.The year 2015 has been a good year for the industry from the direct taxes perspective with the government actively working to simplify the provisions of the Act and clarifying matters of litigation such as applicability of MAT on Foreign Institutional Investors.

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Analysis of decision in case of Rampgreen Solutions Pvt. Ltd.

 

Rampgreen Solutions Pvt Ltd. v CIT, Delhi HC,2015

Introduction

This case law discusses the scope of functional differences filter while carrying out a comparability study for comparables within the same industry sector. The case law has elaborated how companies engaged in Knowledge Process Outsourcing (KPO) services cannot be used as comparables for conducting a Transfer Pricing study of a company engaged in Business Process Outsourcing (BPO) services, even though both KPO and BPO services fall within the broader definition of Information Technology Enabled ServicesSector.

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