Income Tax - Under Transfer Pricing regulation, Safe Harbor rules means binding rules laid down under law which mandates income tax authorities to accept the transfer price declared by the assesse, if opted for. Further section 92CB provides methods for determination of arm’s length price....
Read MoreIncome Tax - The Finance (No. 2) Act, 2014 proposed to introduce a more streamlined method to compute Arm’s Length Price (ALP) in a situation where more than one price is determined, on adoption of Most Appropriate Method(MAM). The first and second provisos were made redundant for all transactions undertaken on or after 01/04/2014. This was done so ...
Read MoreIncome Tax - A transaction in which the buyers and sellers of a product act independently and have no relationship to each other. The concept of an arm's length transaction is to ensure that both parties in the deal are acting in their own self interest and are not subject to any pressure or duress from the other party...
Read MoreIncome Tax - Section 139 of the Act provides for due date of filing return of income in case of various categories of persons. In addition to filing of return of income, the assesses who have undertaken international transactions are also required to prepare and file a Transfer Pricing report in Form 3CEB, as per Section 92E of the Act, before the due...
Read MoreIncome Tax - Notification of Transfer Pricing Rules to incorporate range concept and use of multi-year data to reduce litigation on transfer pricing issues....
Read MoreGemstone Glass Pvt. Ltd Vs Joint Commissioner of Income Tax (ITAT Ahmedabad) - The ITAT Ahmedabad in the case of Gemstone Glass Pvt. Ltd vs. JCIT held that when an associated enterprise is taken as comparable then CUP method cannot be adopted for determining Arm Length Price irrespective of the fact that the associated enterprise taken as comparable is resident or non-resident...
Read MoreM/s. AT & T Global Business Services India Pvt.Ltd. Vs ITO (ITAT Bangalore) - In case of M/s. AT & T Global Business Services India Pvt.Ltd. VS. ITO , assessee-company, engaged in business of software development and providing application services to its AE. TPO on basis of mean margin earned by his own set of comparables...
Read MoreCIT Vs M/s Cotton Naturals (I) Pvt. Ltd. (Delhi High Court) - Assessee had given the loan to the associate enterprise in U.S.D. and in such a situation when the transaction was in foreign currency, and the transaction was an international transactions, then the transaction would have to be looked upon by applying the commercial principles in regard to internat...
Read MoreNotification No. 57/2016-Income Tax - (14/07/2016) - Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the price at which the international transaction or specified domestic transaction has actually been undertaken does not exceed one percent of the latter in respect of wholes...
Read More
Notification No. 57/2016-Income Tax - (14/07/2016) -
Gemstone Glass Pvt. Ltd Vs Joint Commissioner of Income Tax (ITAT Ahmedabad) -
M/s. AT & T Global Business Services India Pvt.Ltd. Vs ITO (ITAT Bangalore) -
CIT Vs M/s Cotton Naturals (I) Pvt. Ltd. (Delhi High Court) -