CA Ram Bajaj

Investing into India through Mauritius

Income Tax - Mauritius is well known as an excellent platform for structuring foreign direct investments into India. Not only does Mauritius benefit from a large network of double taxation avoidance agreements (DTAA), such as the India/Mauritius DTAA, it also has sophisticated legislation and regulations crafted with a view to establishing a well regu...

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Arms Length Price – TNMM PLI Data only regard AE not Whole

Income Tax - What is TNMM Method – TNMM mean Transactional Net Margin Method. It simply state that net profit realized by enterprise from the international transaction with AE should not be less than comparable party having similar transaction. For Example Company a in India having subsidiary at Dubai Company B. ...

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Transfer Pricing : Exclusion of comparable on the basis of High Profit

Income Tax - What is high profit – while determine operating profit for the purpose of TNMM, we have to ascertain the profit earned by enterprise for the basis of comparison. Similarly, we have to ascertain the profit of Compare Company for the purpose of comparison. It is also a part of FAR Analysis....

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FAR Analysis in TP Study

Income Tax - The price charged usually reflects the function that each enterprise performs (taking into account assets used and risk assumed). Comparability analysis of the controlled transaction for the enterprises participating in the controlled transactions provides a basis for characterisation of the controlled transaction to be benchmarked or the...

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International Transaction ALP – Some Issue

Income Tax - 1. Loan given to subsidiary company by Holding Indian Company on Interest – it is covered under sec 92 for the purpose of transfer pricing adjustment. Interest should be charged at LIBOR i.e. London Inter Bank Offer Rate based CUP Method is bench marking in respect of loan given to its subsidiary/AE as decided in Case Laws. ...

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Case Study of Vodafone India services (P) Ltd. Vs UOI (Bombay HC Decision)

Case Study of Vodafone India services (P) Ltd. Vs Union of India (Bombay High court) - Vodafone India Services (P) Ltd. Is a wholly owned subsidiary of Vodafone Tele-Services (India) Holdings Ltd., a non resident company Mauritian entity. Vodafone Holding is AE (Associate Enterprise) of Vodafone India for the purpose of transfer pricing provisions under chapter X of Income Tax Act 196...

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Recent Posts in "CA Ram Bajaj"

Investing into India through Mauritius

Mauritius is well known as an excellent platform for structuring foreign direct investments into India. Not only does Mauritius benefit from a large network of double taxation avoidance agreements (DTAA), such as the India/Mauritius DTAA, it also has sophisticated legislation and regulations crafted with a view to establishing a well regu...

Read More
Posted Under: Income Tax |

Arms Length Price – TNMM PLI Data only regard AE not Whole

What is TNMM Method – TNMM mean Transactional Net Margin Method. It simply state that net profit realized by enterprise from the international transaction with AE should not be less than comparable party having similar transaction. For Example Company a in India having subsidiary at Dubai Company B. ...

Read More
Posted Under: Income Tax |

Transfer Pricing : Exclusion of comparable on the basis of High Profit

What is high profit – while determine operating profit for the purpose of TNMM, we have to ascertain the profit earned by enterprise for the basis of comparison. Similarly, we have to ascertain the profit of Compare Company for the purpose of comparison. It is also a part of FAR Analysis....

Read More
Posted Under: Income Tax |

FAR Analysis in TP Study

The price charged usually reflects the function that each enterprise performs (taking into account assets used and risk assumed). Comparability analysis of the controlled transaction for the enterprises participating in the controlled transactions provides a basis for characterisation of the controlled transaction to be benchmarked or the...

Read More
Posted Under: Income Tax |

Case Study of Vodafone India services (P) Ltd. Vs UOI (Bombay HC Decision)

Case Study of Vodafone India services (P) Ltd. Vs Union of India (Bombay High court)

Vodafone India Services (P) Ltd. Is a wholly owned subsidiary of Vodafone Tele-Services (India) Holdings Ltd., a non resident company Mauritian entity. Vodafone Holding is AE (Associate Enterprise) of Vodafone India for the purpose of transfer pricing provisions under chapter X of Income Tax Act 1961. Vodafone india is engaged in providin...

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International Transaction ALP – Some Issue

1. Loan given to subsidiary company by Holding Indian Company on Interest – it is covered under sec 92 for the purpose of transfer pricing adjustment. Interest should be charged at LIBOR i.e. London Inter Bank Offer Rate based CUP Method is bench marking in respect of loan given to its subsidiary/AE as decided in Case Laws. ...

Read More
Posted Under: Income Tax |

Section 145- Rejection of Books of Account

Problem Faced by Business man as well as Professional :- Stock register as well as details of closing stock in quantitive and rate wise is a major hurdle for both of them. In some business i.e. Labour intensive Work, wholesale and Retail of construction goods releted business, readymade garment business and some other business...

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Posted Under: Income Tax |

Section 14A disallowance Under Income Tax Act, 1961

 CA Ram Bajaj Introduction 1. Section 14A was first inserted by the Finance Act, 2001. However, same was inserted with retrospective effect from 1-4-1962. The inserted section reads as under:— ’14A. Expenditure incurred in relation to income not includible in total income.—For the purposes of computing the total income under th...

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Posted Under: Income Tax | ,

Work Contractor and Rajasthan VAT

CA Ram Bajaj Method of Calculating the Tax liability of VAT in Work Contract:- 1. Exemption Fee Method/Composition Method 2. VAT Method – 1 (Actual labour deduction) 3. VAT Method – 2 (Standard Labour Deduction) Exemption Fee Method /Composition Method – due to complexity of calculation of labour charges and other permissible deduct...

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Posted Under: Income Tax |

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