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Assessee is an employee of a Canadian Company. He went to Canada on 1st March, 2013 and he came back to India on 2nd October, 2013. Then on 17th November, 2013 he again went to Canada and came back on 22nd November, 2013. Assessee was paid salary outside India and that was also in a Bank Account which is also operated outside India. It also to be noted that during the period of stay in India, neither salary was paid in India nor any other payment was received by the employee from the company in India.
Once the Assessing Officer is satisfied that a permanent establishment of the petitioner exists in India and business is being conducted from this permanent establishment, the attribution of profits is a necessary consequence.
Assessee has challenged the addition made by the A.O. and sustained by the ld. CIT(A) by way of TP adjustment on account of interest chargeable on the amount of share application money paid to its AE and lying unutilized for a period beyond 60 days treating the same as loan.
The existing provisions of section 92B of the Act define ‘International transaction’ as a transaction in the nature of purchase, sale, lease, provision of services, etc. between two or more associated enterprises, either or both of whom are non-residents. Sub-section (2) of the said section extends the scope of the definition of international transaction by […]
CBDT in its Instruction No. 2/2014 [F No. 500/33/2013-FTD-l], Dated 26-02-2014 issued in view of the judicial develpments in the cases of GE India Technology P Ltd. vs CIT [2010] 7 taxmann.com and Transmission corporation of AP Ltd v. CIT [1999] 105 Taxmann 742 decided by Supreme Court, has stated that a person who fails […]
This article examines the inter relationship between Transfer Pricing, Entity’s Tax and Financial Reporting. Due to increasing transfer pricing scrutiny, it is being considered as the most risky area for multinational entities from both compliance and tax planning perspective.
Clause 207 relates to foreign tax credit allowable to an assessee, being a resident in India in any financial year on income which is taxed in India as well as outside India. The said clause further provides that where the assessee is required to pay Indian incometax in respect of an income which has been […]
46 Countries under the auspices of OECD adopts a Declaration regarding Automatic Exchange of Information in Tax matters Statement by the Union Finance Minister. May 12, 2014 On May 6, 2014, 46 countries, including India, besides the European Union, meeting under the auspices of the OECD, adopted a Declaration on Automatic Exchange of Information in […]
The obligation of an enterprise to keep and maintain records and documents vis-a-vis the duty of revenue authorities to verify about the compliance with the arm’s length principle has been succinctly stated by the OECD in their Transfer Pricing Guidelines:
Applying the arm’s length principle to review transfer prices set in transactions between associated enterprises often requires a comparison to be made between these prices and the prices set in similar transactions between independent enterprises in similar circumstances.
