Income Tax : Chapter X of the Income Tax Act applies solely to transactions with Associated Enterprises (AEs), excluding non-AE transactions fr...
Income Tax : Uncover the concept of Double Taxation, its types - Juridical and Economic, and learn about relief mechanisms such as Unilateral a...
Income Tax : In Transfer pricing proceedings, corporate guarantee given by assessee to its foreign AE is always disputed by the department as a...
Income Tax : Insider trading, the bane of many Indians who were caught and jailed for their infamous acts is not new to USA. Even in 1700s, Mr....
Finance : This article attempts to dispel the doubts in the minds of such prospective NRI investors by addressing key issues pertaining to p...
Income Tax : India and USA have signed the Inter-Governmental Agreement (IGA) under FATCA in 2015. To enhance the effectiveness of information ...
Income Tax : The Central Board of Direct Taxes (CBDT) is in a fix over the application of one safe harbour rate to all sectors. A committee, fo...
CA, CS, CMA : The Finance Act, 2001 has introduced Sections 92 to 92F in the Income-Tax Act, 1961 with effect from Assessment Year 2002-2003 and...
Income Tax : Learn why a Section 90(1) notification is crucial for a DTAA's enforcement, as per the Supreme Court's landmark judgment in AO vs....
Income Tax : ITAT Delhi held that adoption of Comparable Uncontrolled Price (CUP) method for determining Arm’s Length Price (ALP) of the inte...
Income Tax : ITAT Chandigarh held that the amount of monthly assured return received till the time of possession of units is in nature of inter...
Income Tax : Whether the TPO was legally justified in holding that AMP expenditure was not an international transaction even though the asses...
Income Tax : The issue under consideration is whether the deletion of adjustment made u/s 92CA(3) of the Act on account of interest on loan and...
Chapter X of the Income Tax Act applies solely to transactions with Associated Enterprises (AEs), excluding non-AE transactions from transfer pricing provisions.
Learn why a Section 90(1) notification is crucial for a DTAA’s enforcement, as per the Supreme Court’s landmark judgment in AO vs. Nestle SA. Understand its impact and implications.
Uncover the concept of Double Taxation, its types – Juridical and Economic, and learn about relief mechanisms such as Unilateral and Bilateral relief.
ITAT Delhi held that adoption of Comparable Uncontrolled Price (CUP) method for determining Arm’s Length Price (ALP) of the international transaction is unjustified.
ITAT Chandigarh held that the amount of monthly assured return received till the time of possession of units is in nature of interest is taxable @15% under Article 12 of India-UK DTAA
In Transfer pricing proceedings, corporate guarantee given by assessee to its foreign AE is always disputed by the department as an international transaction and adjustment determined on the basis of average bank guarantee rates. However, in number of judgements by tribunal and HC, the stand of the department is overruled and relief granted to the assessee.
Whether the TPO was legally justified in holding that AMP expenditure was not an international transaction even though the assessee was performing DEMPE functions for its AE and doing activity of brand building?
Insider trading, the bane of many Indians who were caught and jailed for their infamous acts is not new to USA. Even in 1700s, Mr. Nilliam Duer, Assistant Secretary, Treasury Department of Federal Government, USA, used his position to guide the purchase of bonds. This article intends to guide its evolution, current rules and show […]
The issue under consideration is whether the deletion of adjustment made u/s 92CA(3) of the Act on account of interest on loan and on account of corporate guarantees is justified in law?
India and USA have signed the Inter-Governmental Agreement (IGA) under FATCA in 2015. To enhance the effectiveness of information exchange and transparency, both the sides committed to establish, by January 1, 2017, rules requiring their Reporting Financial Institutions (RFIs) to obtain the Tax Identity Number (TIN) of each report able person having a report able account as of June 30, 2014 (pre- existing account).
