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Kunal Aggarwal

Latest Posts by Kunal Aggarwal

No adjustment if impact of outstanding receivable considered in Working Capital

August 20, 2019 3261 Views 0 comment Print

M/s. Barco Electronic Systems (P.) Ltd. Vs. DCIT (ITAT Delhi) Facts of the Case ♣ Barco Electronic Systems Pvt. Ltd. ( taxpayer) is engaged in business of manufacturing of projectors and parts, trading in visual display products and provision of software development services. ♣ During the year under consideration, the taxpayer entered into various international […]

Concept of Secondary Adjustment & changes proposed in Finance bill 2019

July 31, 2019 3552 Views 0 comment Print

♣ Secondary Adjustment has been inserted vide section 92CE by the Finance Act, 2017, in order to align TP provisions with OECD TP Guidelines and “international best practices”. ♣ Secondary adjustment means an adjustment in the books of accounts of the taxpayer and its associated enterprise (‘AE’) to reflect that the actual allocation of profits […]

Penalties under Transfer Pricing Provisions

July 23, 2019 17298 Views 0 comment Print

The Income tax Act 1961, has prescribed penal provisions for default in compliance with the provisions of the a TP regulations, which are summarized below: Nature of default Relevant Section of the Act Nature of penalty Under Reporting of income arising in the cases other than the case referred in sub section (9) 270A(2) read […]

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