Income Tax : Delve into the complexities of digital taxation, exploring its evolution, significance, and global responses. Learn about fair ta...
Income Tax : Discover the intricacies of structuring cross-border mergers and acquisitions (M&A). Learn about key steps, due diligence, legal c...
Income Tax : Country-by-Country Reporting (CbCR) is a crucial component of the transfer pricing documentation requirements introduced by the Or...
Income Tax : Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs...
Income Tax : Explore the significance of transfer pricing in international taxation and corporate finance. Learn about arm's length pricing, me...
Income Tax : What is the procedure to approve Form 3CEB? Form uploaded by CA shall be available under For your action tab in Taxpayer’s Workl...
Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...
Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...
Income Tax : Voice Of CA has made a Request for Extension of specified date of filing Tax Audit Report and other forms falling due on or before...
Income Tax : Chamber of Tax Consultants has made a Request for Extension of Due Dates for filing Tax Audit and Transfer Pricing Reports to Smt....
Income Tax : Issuance Of Letters Of Comfort/Support will Construe As International Transaction U/s 92B considering corporate guarantee issued b...
Income Tax : Read the full text of ITAT Mumbai's order in the case of LANXESS India Pvt Ltd vs DCIT, upholding TNMM method over CUP for benchma...
Income Tax : Read the Delhi High Court judgment on PCIT vs Mercer Consulting India Pvt. Ltd. regarding transfer pricing provisions and intra-gr...
Income Tax : Ahmedabad ITAT's order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. De...
Income Tax : In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Co...
Income Tax : Stay informed on the latest Income Tax Rule changes with Notification No. 104/2023 by the Ministry of Finance. Learn about amendme...
Income Tax : Read how CBDT's Notification No. 58/2023 amends Income-tax Rules, extending Safe Harbour rules to AY 2023-24. Insights from Minist...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
Income Tax : In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act, 1961 (43 of 1961...
Income Tax : Safe Harbour rules for AY 2022 2023 | Income tax Act, 1961 | Notification No. 66/2022-Income-Tax | Dated: 17th June, 2022 | CBDT...
Learn about Mutual Agreement Procedures (MAP) and how they help resolve double taxation and non-taxation issues in cross-border transactions.
Mutual Agreement Procedure is a dispute resolution mechanism in which taxpayer resorts to solving disputes relating to double taxation-juridical or economic.
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.
GE India Business Services Pvt. Vs DC/ACIT IT (ITAT Delhi) Facts- The assessee company GE India Business Services Pvt. Ltd. is set up as a captive service provider to provide offshore outsourcing services primarily to GE entities/ business worldwide. The primary activity in which Assessee Company specializes is to render IT Enabled Services (“ITES”) and […]
ACIT Vs Electrosteel Casting Ltd. (ITAT Kolkata) It is clear from the rival contentions that determination price at which Power generated can be sold is subject to statutory control under the provisions of Section 61 & 62 of the Electricity Act, 2003. The Hon’ble Calcutta High Court in its decision rendered in the case of […]
Multinational corporations are continuing to play an increasingly crucial role in international trade which directly affects taxation issues. Tax administrations as well as multinational corporations have felt the heat of such taxation issues and the global community has come to a consensus that such issues must be considered at a global scale instead of a narrow domestic context.
TPO /DRP in their order has expressed an inability to compute the ALP using CUP due to a lack of information in the public domain. Given the difficulty / impossibility in computing ALP using CUP and considering the close nexus between the manufacturing activity and payment of management / license fees, the method to be adopted for benchmarking the above international transactions by the assessee ought to be TNMM.
Uncover the mysteries of transfer pricing and associate enterprises. Explore the etymology and concepts behind international and domestic transactions.
Through this article, we aim to uncover the probable rationale and takeaways from this acquisition, for which we need to first understand the ownership structure of both the groups – Holcim and Adani.
Capgemini India Pvt. Ltd. Vs DCIT (ITAT Mumbai) Facts- Assessee filed its return of income on 7 October 2010 declaring income of ₹113,19,82,875/-. As the assessee has entered into several international transactions, reference was made to the Learned Additional Commissioner of Income-Tax, Transfer Pricing, 1(3), Mumbai for determination of arm’s length price of those transactions. […]
