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Income Tax - Applicability of transfer pricing provisions was earlier limited to International Transactions only. With effect from 01.04.2013, the scope of Transfer Pricing provisions is extended to 'Specified Domestic Transactions' and is accordingly applicable from A.Y. 2013-14....
Read MoreIncome Tax - The provisions of transfer pricing are designed to keep a check on the practice of reducing the tax liability by entering into transactions at prices higher/lower than market prices with one or more associated entity....
Read MoreIncome Tax - AS 18 defines the disclosure requirements related to related party relationship and transaction between a reporting enterprise and its related parties in the financial statement of that enterprise. The basic assessment during disclosure is centered upon two things viz., who is related party and what amounts to related party transaction. A...
Read MoreIncome Tax - 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....
Read MoreIncome Tax - Transfer pricing provisions were earlier restricted to international transactions. With effect from 1.4.2013 , the scope of transfer pricing provisions gets extended to specified domestic transactions (SDT) exceeding Rupees twenty crore....
Read MoreDCIT Vs Convergys Customer Management Group Inc. (ITAT Delhi) - DCIT Vs Convergys Customer Management Group Inc. (ITAT Delhi) It is mandatory for all taxpayers, without exception, to obtain an independent accountant’s report in respect of all international transactions between associated enterprises or specified domestic transactions. The report has to be ...
Read MoreM/s. Bhartia-SMSIL (JV) Vs ITO (ITAT Guwahati) - Since clause (i) section 92A was omitted with effect from 1st April, 2017 and the effect of such omission is that the said clause(i) was never existed in the statute. Hence, Ld. PCIT can not exercise the jurisdiction u/s 263 of the Act....
Read MoreAshish Subodhchandra Shah (HUF) Vs PCIT (ITAT Ahmedabad) - Merely because a prescribed Form No. 3CEB was filed in accordance with Rule 10E r.w.s. 92BA of the Act would not make an assessee susceptible to onerous investigation proceedings on such transactions where the assessee prima facie demonstrates that Section 92BA of the Act is wholly inapplicable in a...
Read MoreTimes Global Broadcasting Company Ltd vs. Union of India & Ors. (Bombay High Court) - Hon’ble Bombay High Court (HC) held that the transfer pricing officer (TPO) cannot suo-motu assume jurisdiction to determine the arm’s length price (ALP) of specified domestic transactions (SDT) not referred to him....
Read MoreACIT Vs HDFC Bank Ltd. (Bombay High Court) - Transaction of purchase of loan from HDFC ltd. would not cover within the meaning of Specified Domestic Transactions (SDTs) as the shareholding of HDFC Ltd. of 16.39% could not be clubbed with the shareholding of the HDFC Investments Ltd. of 6.25% to cross the threshold limit of substantial interest...
Read MoreNotification No. 4 of 2018-DGIT(S) - (05/04/2018) - Procedure for registration and submission of Statement of Reportable Account as per section 285BA of Income-tax Act, 1961 read with Rule 114G of Income-tax Rules, 1962. ...
Read MoreNotification No. 3 of 2018-DGIT(S) - (05/04/2018) - Procedure for registration and submission of statement of financial transactions (SFT) as per section 285BA of Income-tax Act, 1961 read with Rule 114E of Income-tax Rules, 1962. ...
Read MoreNotification No. 2 of 2018-DGIT(S) - (05/04/2018) - As per sub-rule (1)(i) and sub-rule (4) of Rule 114D, the statement in Form No. 61 shall be furnished through online transmission of electronic data to a server designated for this purpose and in accordance with the data structure specified in this regard by the Principal Director General of Income-...
Read MoreNotification No. 1 of 2018-DGIT(S - (05/04/2018) - Under electronic verification, the individual or a person (not being a company or firm) who does not have a permanent account number and who enters into any transaction specified in under Rule 114B of the Income-tax Rules, 1962, shall make a declaration in Form No. 60 giving therein the particulars ...
Read MoreInstruction No. 3/2016 - (10/03/2016) - In terms of the provisions, any income arising from an international transaction or specified domestic transaction between two or more associated enterprises shall be computed having regard to the Arm's Length Price....
Read MoreDCIT Vs Convergys Customer Management Group Inc. (ITAT Delhi) -
M/s. Bhartia-SMSIL (JV) Vs ITO (ITAT Guwahati) -
Ashish Subodhchandra Shah (HUF) Vs PCIT (ITAT Ahmedabad) -
Times Global Broadcasting Company Ltd vs. Union of India & Ors. (Bombay High Court) -
ACIT Vs HDFC Bank Ltd. (Bombay High Court) -
