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Income Tax - With respect to opening WDV in case of the foreign company whose PoEM is determined in India and which is assessed to tax in the home jurisdiction, the final notification provides for 2 cases:...
Read MoreIncome Tax - The CBDT has issued the Final Notification No. 29/2018 dated 22 June 2018 (applicable from AY 2017-18) for exception, modification and adaptation in respect of a foreign company said to be resident in India due to its place of effective management (POEM) being in India, under Section 115JH of the Income-tax Act, 1961 (the Act). […]...
Read MoreIncome Tax - Draft Notification of exception, modification and adaptation in respect of foreign company said to be resident in India under section 115JH of the Act The Central Board of Direct Taxes (CBDT) on June 15, 2017 issued a Draft Notification (notification) vide F No. 370142/19/2017-TPL for exception, modification and adaptation in respect of f...
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 - The revised SHRs apply for AY 2017-18 and two immediately following AYs i.e. upto AY 2019-20. The earlier SHRs were applicable from AY 2013-14 and four immediately following AYs i.e. upto AY 2017-18. For AY 2017-18, the taxpayer can choose from old or new rules whichever are more beneficial....
Read MoreIncome Tax - The Finance Act 2012 has introduced DTP in spite of existing provisions under the Act which empower the Assessing Officer (AO) to re-compute the income of assessees availing profit-linked deductions if there are transactions with related parties or other undertakings of the same assessee...
Read MoreIncome Tax - Clarification of India’s position on the acceptance of MAP and bilateral APA in cases of countries where Article 9(2) of OECD Model Tax Commentary is absent...
Read MoreIncome Tax - ICAI has released the 6th Edition (November 2017) of the Guidance Note on Report Under Section 92E of the Income Tax Act, 1961 (Transfer Pricing). This Guidance Note was previously revised in February, 2013 , August 2013 and October 2016. The ICAI has revised Guidance note on Report under Section 92E of the Income Tax […]...
Read MoreIncome Tax - This report sets out the 10 essential principles for effectively fighting tax crimes. It covers the legal, institutional, administrative, and operational aspects necessary for putting in place an efficient system for fighting tax crimes and other financial crimes. It draws on the insights and experience of jurisdictions around the world. ...
Read MoreIncome Tax - This report describes the current position in 51 countries as to the law and practice for domestic inter-agency co-operation in fighting tax crimes and other financial crimes including, for the first time, co-operation with authorities responsible for the investigation and prosecution of corruption. It identifies successful practices base...
Read MoreACIT Vs Johnson & Johnson Ltd ( ITAT Mumbai) - Production loss depends on number of factors and in absence of any comparable to show that loss shown by the assessee is excessive, the contention of the assessee has to be accepted...
Read MoreM/s. Nokia Networks OY vs. JCIT (ITAT Delhi) - Whether the Indian subsidiary of the assessee constitutes Permanent Establishment (PE) of the assessee in India on account of ‘signing, networking, planning and negotiation of offshore supply contracts in India’? If yes, whether any profit is attributable to the same, and the quantum thereof?...
Read MoreM/s Mitchell Drilling India Vs DCIT Circle-6(1) (ITAT Delhi) - Mitchell Drilling India Private Limited vs. DCIT (ITAT Delhi) It is elementary that the ALP is determined of an `international transaction’, which has been defined in section 92B of the Act. The term `transaction’, for the purposes of the Chapter–X containing transfer pricing provisions, has ...
Read MoreAxis Risk Consulting Services Private Limited.Vs DCIT (ITAT Delhi) - Axis Risk Consulting Services Private Limited. Vs DCIT (ITAT Delhi) the only dispute before us is with regard to the adjustment by way of imputing interest @ 17.22% by the TPO on account of receivables from the AE. Here in this case, it is an undisputed fact that the assessee has also rendered simil...
Read MoreITO v. Nihon Parkerizing (India) (P.) Ltd. (ITAT Delhi) - Hon’ble ITAT upheld the position of law as iterated by CIT (A) that it is an established law applicable for imposition of penalty that law, as in force, at the time of filing of Return would be applicable. ...
Read MoreF. No. 370142/12/2017-TPL - (19/06/2018) - Amendment in Rule 10CB of Income-tax Rules, 1962 in respect of computation of interest income pursuant to secondary adjustment made under section 92CE of Income-tax Act, 1961 – Comments and suggestions ...
Read MoreF.No.370142/34/2016-TPL (Part) - (10/04/2018) - Draft notification proposing an amendment to rule 44E, Form 34C, 34D and 34DA as per BEPS action item 5, for improving transparency in relation to tax rulings– comments and suggestions...
Read MoreNotification No. 92/2017 / S.O. 3497(E) - (31/10/2017) - Information and documents to be kept and maintained under proviso to sub-section (I) of section 92D and to be furnished in terms of sub-section (4) of section 92D. 10DA. (1) Every person, being a constituent entity of an international group shall,-...
Read MoreF. No. 370142/25/2017-TPL - (06/10/2017) - It is proposed to insert rulac 10DA, 10DB and form nos. 3CEBA to 3CEBE in the Income-tax Rules, 1962 (`the Rules'), laying down the guidelines for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country report. In this regard, the following guidelines a...
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...
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ACIT Vs Johnson & Johnson Ltd ( ITAT Mumbai) -
F. No. 370142/12/2017-TPL - (19/06/2018) -
M/s. Nokia Networks OY vs. JCIT (ITAT Delhi) -
M/s Mitchell Drilling India Vs DCIT Circle-6(1) (ITAT Delhi) -
Axis Risk Consulting Services Private Limited.Vs DCIT (ITAT Delhi) -
