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Income Tax - The Indian Central Board of Direct Taxes (CBDT) has notified the final rules (the rules) for maintaining and furnishing of Transfer Pricing (TP) documentation in the Master File (MF) and Country-by-Country Report (CbCR). Following an inclusive approach when introducing a new and important regulation, the CBDT had...
Read MoreIncome Tax - Transfer pricing (TP) regulations have been at the forefront of corporate headlines over the last few years due to the increasing number of controversies resulting out of tax structuring by multinational companies (MNE). What makes the topic both contentious and interesting is that regulators view the various techniques applied to interco...
Read MoreIncome Tax - In order to curb structuring by the multinational group Companies having their presence through subsidiaries/ associate companies or permanent establishments in India, the Finance Act 2017 introduced a new section 94B under the Income-tax Act, 1961 (the Act), in line with the recommendations of OECD BEPS Action Plan 4...
Read MoreIncome Tax - The CBDT has released the final rules through notification (N No. 3497(E) on preparation and filing of Master file by the Constituent Entity of an International group. The brief of the rules as notified and the documentation requirements as needed for the filing are summarized below:...
Read MoreIncome Tax - The Central Board of Direct Taxes (CBDT), has released the final rules through a notification (N No. 3497(E) on preparation and filing of Master file by the Indian Entity of an International group. The brief of the rules as notified and the documentation/information requirements as needed for the filing are summarized herewith for your re...
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 MoreApprova Systems Pvt. Ltd Vs. DCIT (ITAT Pune) - Approva Systems Pvt. Ltd Vs. DCIT (ITAT Pune) Now, coming to the second claim of deduction under section 10B/10A of the Act on TP adjustment of Rs 64,07,399/-. The assessee on its own motion had offered adjustment on account of transfer pricing provision to the extent of Rs 64,07,399/-. The computat...
Read MorePr CIT Vs. Verizon India Pvt. Ltd (Delhi High Court) - In the absence of any overt act, which disclosed conscious and material suppression, invocation of Explanation 7 to s. 271(1)(c) in a blanket manner could not only be injurious to the assessee but ultimately would be contrary to the purpose for which it was en grafted in the statute....
Read MoreDabur India Ltd. Vs. Pr. Commissioner of Income Tax- III (Delhi High Court) - A two-Judge Bench of the Delhi High Court in Dabur India Ltd. vs. Pr. Commissioner of Income Tax held that Transfer Pricing adjustment is applicable to overseas subsidiary despite of receiving any royalty. ...
Read MoreTexport Overseas Private Limited vs. DCIT (ITAT Bangalore) - Whether the omission of reference of section 40A(2)(b) from section 92BA by virtue of the amendment of Finance Act, 2017 w.e.f. 01.04.2017 shall be deemed not to be on the statute since its introduction w.e.f. 01.04.2012?...
Read MoreVodafone India Services Pvt Ltd Vs. DCIT (ITAT Ahmedabad) - Vodafone India Services Pvt Ltd Vs. DCIT (ITAT Ahmedabad) 97. The question that we really need to address ourselves to is whether the above arrangement constitutes an ‘international transaction’. However, before we do so, it is only appropriate that we take a look at the relevant definitions u...
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...
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...
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Approva Systems Pvt. Ltd Vs. DCIT (ITAT Pune) -
F.No.370142/34/2016-TPL (Part) - (10/04/2018) -
Pr CIT Vs. Verizon India Pvt. Ltd (Delhi High Court) -
Dabur India Ltd. Vs. Pr. Commissioner of Income Tax- III (Delhi High Court) -
