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Income Tax - Transfer Pricing Regulations is an internationally accepted method to check that multinational enterprises entering into transactions with associated enterprises do not evade taxes by undervaluing the transaction. The purpose and ambit of Transfer Pricing Regulations is to ensure that international transactions between associated enterpri...
Read MoreIncome Tax - In this article you will find detailed analysis of certain terms and issues which either OECD or certain other countries have clarified. Notification in respect of BEPS Action plan 13 is expected shortly from CBDT. ...
Read MoreIncome Tax - CbCR (Country by Country Report) is one of the recent amendment which has created a lot of hue and cry in the industry, hence here in this article the author will provide the basic concepts related to CbC reporting for all the Chartered Accountants. ...
Read MoreIncome Tax - Section 92CB of the Income Tax Act 1961 provides that the determination of arm’s length price under Section 92C OR 92CA. However, same shall be subject to Safe Harbour Rules. Sections 10 TA to 10 TG deals with the Safe Harbour Rules, which pertain to International Transactions. Rule 10TE provides a detailed procedure for exercise [&hell...
Read MoreIncome Tax - The taxation regime in India seems to be undergoing crucial changes to negate the above quote from one of the greatest philosophers of all times. On this backdrop, the principles of thin capitalisation as prescribed in the Organization for Economic Cooperation and Development (‘OECD’) Base Erosion and Profit Shifting (‘BEPS) Action ...
Read MoreIncome Tax - Following is the Exposure Draft of the Guidance Note on Report under section 92E of the Income-tax Act, 1961 (Transfer Pricing), issued by the Committee on International Taxation of ICAI for comments. Changes have been made to the extent of amendments made by the Finance Act, 2017....
Read MoreIncome Tax - Cabinet approves signing of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting by India...
Read MoreIncome Tax - ICAI has released the 5th Edition (November 2016) of the Guidance Note on Report Under Section 92E of the Income Tax Act, 1961 (Transfer Pricing). ...
Read MoreIncome Tax - The results of a recently conducted global survey of 2,600 businesses in 36 countries, finds little impact from the OECD BEPS programme which was finalised last October, as 78 percent of the surveyed businesses said that they have not changed their businesses approach to taxation, despite more than 80 countries having agreed to adopt at l...
Read MoreIncome Tax - On February 17, 2016, the Treasury Department released a revised 2016 U.S. Model Income Tax Convention (the 2016 Model), which is the baseline text the Treasury Department uses when it negotiates tax treaties. The U.S. Model Income Tax Convention was last updated in 2006 (the 2006 Model). This preamble highlights the significant features ...
Read MoreCummins Turbo Technologies Ltd. Vs DCIT (ITAT Pune) - ITAT held that on account of extra ordinary events viz. acquisition of IQ group of companies and amalgamation of Accentia Infoserve Pvt. Ltd with Accentia Technologies Ltd, the said company cannot be considered as good comparable. ...
Read MorePr. CIT -V Vs Kusum Health Care Pvt. Ltd. (Delhi High Court) - Transfer Pricing : Impact of delayed associated enterprise receivables subsumed in working capital adjustment made by the assessee company. Delhi High Court confirms ITAT’s deletion of notional interest adjustment on delayed AE-receivables....
Read MoreEvonik Degussa India (P.) Ltd. Vs. Deputy Commissioner of Income Tax (OSD) (ITAT Mumbai) - 1. Research and development services provider could not be compared to a company and Transfer pricing Adjustment are not sustainable. 2. A concern mainly engaged in sale of chemical compounds could not be considered as a right comparable with that of assessee rendering support services in connectio...
Read MoreHyundai Motor India Limited Vs Deputy Commissioner of Income Tax LTU- II (ITAT Chennai) - The first question that we need to decide is whether the benefit accruing to the HMC Korea, as a result of increased brand value due to sale of Hyundai cars in India by the assessee company, constitutes an international transaction....
Read MoreZee Entertainment Enterprises Ltd Vs The Addl Commissioner of Income Tax (ITAT Mumbai) - Transfer Pricing Officer has selected RPM as most appropriate method for determining the arm's length price of the transaction of sale of programmes and film rights to ATL in contrast to the TNM method selected by the assessee. The first controversy is as to whether the Transfer Pricing Officer was ...
Read MoreNotification No. 62/2017-Income Tax - (18/07/2017) - These rules may be called the Income-tax (21st Amendment) Rules, 2017.They shall come into force and shall be deemed to have come into force from the 1st day of April, 2017. In the Income-tax Rules, 1962, in Appendix II, in Form No. 3CEFA, in paragraph 2, under the heading Eligible International Tra...
Read MoreF No 370142/19/2017-TPL - (15/06/2017) - CBDT invites comments and suggestions on the Draft Notification in respect of foreign company said to be resident in India under Section 115JH of the Income-tax Act, 1961...
Read MoreNotification No. 50/2017-Income Tax - (09/06/2017) - Central Government hereby notifies that where the variation between the arm's length price determined under section 92C of the Act and the price at which the international transaction or specified domestic transaction has actually been undertaken does not exceed one per cent of the latter in respect...
Read MoreNotification No. 46/2017-Income Tax - (07/06/2017) - The lukewarm response to the earlier safe habour scheme was on account of the high rates. Thus, taxpayers opted for unilateral APA process instead. The revised scheme has been designed to attract small to medium business, especially in IT/ITeS segment, so as to give them a viable alternative to APA...
Read MoreNotification No. 57/2016-Income Tax - (14/07/2016) - Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the price at which the international transaction or specified domestic transaction has actually been undertaken does not exceed one percent of the latter in respect of wholes...
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Notification No. 62/2017-Income Tax - (18/07/2017) -
