NEWS 1. Signing of Inter-Governmental Agreement for exchange of country by country reports between India and the United States of America-Press release dated 27.03.2019. 2. CBDT notifies ‘Nodal Officer, PM-KISAN’ for furnishing specified information u/s 138 [Ref:-Notification S.O. 1065(E) [NO.12/2019 (F.NO.FEMA 20(R)5/2019-RB)], Dated 27-2-2019] 3. CBDT extends term of Task Force on Direct Tax by 3 […]
TAX UPDATES – DECEMBER 2018 NEWS 1. CBDT vide Notification dated 06th December, 2018 notifies the norms for conversion of Branch of Foreign Banks in India into Subsidiary Company. [Notification No. 85/2018/F.No.370133 /34/2016-TPL] 2. CBDT vide Notification 06th December, 2018 further clarifies that no tax deduction at source u/s 194A of the Income Tax Act, […]
Hon’ble ITAT upheld the position of law as iterated by CIT (A) that it is an established law applicable for imposition of penalty that law, as in force, at the time of filing of Return would be applicable.
Margins derived on export of parts to AE are not comparable with the margins derived from sales made in the domestic market. Besides, on facts, it was also found that not only the parts and finished goods are not comparable, but the class of customers to whom they sold is also different.
Pursuant to the amendment made by Finance Act 2017, omission of clause (i) of Section 92BA of the IT Act, 1961 be deemed to be removed from statute since the beginning until and unless there is some saving clause or provision that pending proceedings shall be continued and be disposed off under old rules.
ITAT Bengaluru held in the case of Nuance Transcription Services India (P.) Ltd. v Dy. CIT that Outstanding Receivables from AE is an international transaction as per Explanation to Section 92B inserted by the Finance Act 2012 and non-charging of interest for a period exceeding 6 months requires ALP adjustment.
In India, new transfer pricing rules were introduced in 2002. Since then, the number of cases identified for audit and the transfer pricing adjustments locked up in disputes have increased tremendously. In order to reduce the increasing number of transfer pricing audits and prolonged disputes
Finance Act, 2012 has made an amendment to extend the Transfer Pricing Provisions to the transactions entered with domestic related parties or by an undertaking with other undertakings of the same entity for the purposes of section 40A, chapter VI-A and section 10AA.
Hon’ble Supereme Court admits SLP- Transer pricing adjustment should be restriced to AE transactions only and not on entire turnover of assessee
On 10th May 2016, the Government of India has issued a press release announcing the Protocol for amendment of the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains between India and Mauritius (DTAA).
