Income Tax : Explore the concept of transaction recharacterization in transfer pricing. Understand its rationale, benefits, and challenges in g...
Income Tax : Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023....
Income Tax : India's Transfer Pricing regulations for FY 2023-24 (AY 2024-25) - This detailed chart lists key activities, legal sections, requi...
CA, CS, CMA : Learn about transfer pricing, its importance, methods, documentation, penalties for non-compliance, and advanced pricing agreement...
Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...
Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : ITAT Hyderabad directed to exclude companies having turnover of more than or less than 10 times of the turnover of the assessee fr...
Income Tax : ITAT Mumbai held that no transfer pricing adjustment could have been made in the hands of assessee on account of ALP of specified ...
Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...
Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...
Income Tax : ITAT Delhi rules RPM as the best method for benchmarking solar goods purchases in the D Light Energy P. Ltd. vs Assessing Officer ...
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...
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. […]
Understand the complexities of AMP expense as an international transaction. Learn about the deductions allowed under the Income Tax Act for advertising, marketing, and promotion expenses.
Two key developments occurred in the twenty-first century: India’s fast expansion in commerce and investment, and the establishment of international supply chains, which facilitated the manufacturing, sale, and redistribution of items to take place in several nations.
Learn the importance of benchmarking in the Indian context and how it is used to determine fair pricing in transfer transactions.
Amidst the OECD’s inclusionary efforts, many issues remain unresolved, particularly when it comes to the transfer of intangibles for the specific purpose of business restructurings. Cross-border transfers of intangibles are frequently made with the final goal of changing corporate structures, such as when a company is entirely comprised of this type of assets (IP company).
