group company

The industry ministry today said it will come out with a definition of ''group company'' soon, a clarification that would help global companies like Wal-Mart to begin operations without violating norms. "We are working on a clarification. Full Article

The Taxpayer incurred interest expenditure on the funds borrowed for investing in shares of a company, with a view to acquire controlling interest. The ITAT held that the interest expenditure incurred is not allowable under Section 57(iii)(Section) of the Indian Tax Law (ITL), since it is not incurred 'wholly and exclusively' for the purpose of earning dividend income. Full Article

Cable & Wireless Networks India Private Limited („the applicant?) is engaged in the business of providing international and domestic long distance telecommunication services in India. It proposes to enter into an agreement with its group company, Cable and Wireless UK („C&W UK?) to provide end to end international long distance telecommunication services to its Indian customers. Full Article

One of the most widely contested issues by Indian tax authorities during a transfer pricing audit is the amount paid for intra-group services to group companies often referred to as management or intra-group fees/charges. In fact, compensation for intra-group services has been one of the important transfer pricing challenges globally for taxpayer and authorities alike. Full Article

The applicant is a US-based manufacturer engaged in manufacturing of engineering goods and is also an R&D-based service provider. It entered a cost al ocation agreement with its India-based group company. The applicant raises invoices on the Indian group company for services rendered based on the formula given in the agreement. The question before the Authority for Advance Ruling was: “Whether payments made for availing services listed out in the agreement are taxabl.. Full Article

This article summarizes a recent ruling of the Mumbai Income Tax Appellate Tribunal (ITAT) in the case of Panatone Finvest Ltd.(Taxpayer) [2009-TIOL-717-ITAT-MUM]. The Taxpayer incurred interest expenditure on the funds borrowed for investing in shares of a company, with a view to acquire controlling interest. The ITAT held that the interest expenditure incurred is not allowable under Section 57(iii) (Section) of the Indian Tax Law (ITL), since it is not incurred ‘wh.. Full Article

SUMMARY OF CASE LAW Where the transaction relating to transfer of lease hold rights of immovable property between the assessee and its group company was complete in the year 2001-02 itself in terms with the provisions of section 2(47)(v) of IT Act, 1961 read with section 53A of the TP Act, 1882, the capital gain [...] Full Article