Income Tax : SDT includes payments to related parties, inter-unit transfer of goods or services of profit linked tax holiday-eligible units, tr...
Company Law : As per this circular, PAN is compulsory for a Foreign National who is a subscriber / promoter at the time of incorporation of the ...
Income Tax : In pursuance of the changes made by the Finance Bill 2012 bringing specified domestic transactions under the ambit of Transfer Pri...
Income Tax : CBDT Explains APA through a press release. Indian APA Scheme Notifies Three Types of APA unilateral, bilateral and multilateral. P...
Income Tax : Vide Notification No. 36 of 2012, in exercise of the powers conferred by sub-section (9) of section 92CC read with section 295 of ...
Income Tax : The Australian Senate has passed legislation on the application of transfer pricing rules, designed to ensure that multinational c...
Income Tax : Australian Finance Ministry passes Tax Law Amendment (Cross Border Transfer Pricing Bill) Act (No. 1) 2012 with retrospective 01 J...
Income Tax : Whether on facts and circumstances of the case and in law, the ITAT was justified in deleting the disallowance made of royalty pai...
Income Tax : In a writ petition filed by small investors, Karnataka High Court Held that provisions of Section 206AA of the Income Tax Act are ...
SDT includes payments to related parties, inter-unit transfer of goods or services of profit linked tax holiday-eligible units, transactions of profit-linked tax holiday-eligible units with other parties and any other transaction that may be notified by the Central Board of Direct Taxes.
As per this circular, PAN is compulsory for a Foreign National who is a subscriber / promoter at the time of incorporation of the company. However, if the Foreign National does not possess a PAN, then he / she is required to furnish a declaration / undertaking in prescribed format as an attachment to Form INC – 7 at the time of incorporation of the company.
In pursuance of the changes made by the Finance Bill 2012 bringing specified domestic transactions under the ambit of Transfer Pricing Regulations, CBDT has amended the format of Form 3CEB vide notification number 41 dated 10 June 2013. The said notification also amends Rule 10A, 10AB, 10B, 10C, 10D and 10E.
CBDT Explains APA through a press release. Indian APA Scheme Notifies Three Types of APA unilateral, bilateral and multilateral. Press Release clarifies that the choice is on the applicant to choose a particular type of APA at the time of making the application.
Vide Notification No. 36 of 2012, in exercise of the powers conferred by sub-section (9) of section 92CC read with section 295 of the Income-tax Act, 1961 (43 of 1961), the Central Board of Direct Taxes releases Advance Pricing Agreement Scheme. The advance pricing agreement scheme shall be governed by Rules 10F to Rule 10T.
The Australian Senate has passed legislation on the application of transfer pricing rules, designed to ensure that multinational companies pay their ‘fair share’ of tax. The Tax Laws Amendment (Cross-Border Transfer Pricing) Bill (No. 1) 2012 was put forward before the house of Representatives in June 2012.
The prima-facie role of a Company Secretary is to identify all the AEs with whom the Company has transacted during the year. There are likely chances that some of the entities which are falling under the deeming fiction might go unnoticed to the auditors. The consequence of non-reporting of a transaction is as high as 2 % of the total value of transaction that went unreported. Further, penalty proceedings can also be initiated for concealment of true facts and disclosure under section the Income Tax Act.
Whether on facts and circumstances of the case and in law, the ITAT was justified in deleting the disallowance made of royalty paid by the respondent to CAMI USA for distribution of software products in India without appreciating that the royalty had been paid on the amount of bad debts even where the software had not worked at all?”
Transfer pricing until now was applicable to companies having cross border transactions with their ASSOCIATED ENTERPRISE. However, Finance Bill 2012, honoring the supreme court ruling in case of CIT vs. M/S Glaxo Smithkline Asia (P) Ltd. (Special Leave to Appeal (Civil) No(s).18121/2007), expanded the ambit of transfer pricing to specified domestic transactions w.e.f 01 April 2013.
Australian Finance Ministry passes Tax Law Amendment (Cross Border Transfer Pricing Bill) Act (No. 1) 2012 with retrospective 01 July 2004. The Tax Law Amendment (Cross Border Transfer Pricing Bill) Act (No. 1) 2012 was passed by the house of representatives without amendments on 19 June 2012.
