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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : In the case of Honda Motorcycle & Scooter India Pvt Ltd vs. ACIT, ITAT Delhi directed the Transfer Pricing Officer (TPO) and Asses...
Income Tax : Delhi High Court rules AO can't deviate from Transfer Pricing Officer's determined Arm's Length Price (ALP) in international trans...
Income Tax : Learn from PCIT Vs Radhashir Jewellery Co. Pvt Ltd. case why comparing new and established businesses in transfer pricing is inapp...
Income Tax : Analysis of Maharashtra Seamless Ltd Vs DCIT case where no transfer pricing adjustment was needed as the assessee earns interest a...
Income Tax : Delhi High Court rules in favor of Oriflame India Pvt Ltd, withdrawing TPO's proposed income adjustments, applies TNMM over RPM. D...
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...
CBDT) has issued the final rules pertaining to Master File (MF) and Country by Country reporting (CbCR) on 31st October 2017. This is an outcome of the OECD/G20 BEPS Action Plan 13. India has been an active participant of the OECD BEPS (Base Erosion and Profit Shifting) project.
Lambda Therapeutic Research Ltd. Vs DCIT (ITAT Ahmedabad) We find that the assessee has not demonstrated any benefit derived from its associated enterprises namely Lambda USA whereas it has advanced interest free loan of EURO 49,999/-. Thus, the question arises whether there is a need to make any adjustment on account of notional interest under […]
ALP of corporate guarantee has to be determined as it falls within scope and ambit of an international transaction after retrospective amendment to section 92B and 0.5% corporate guarantee is held to be appropriate.
DCIT Vs Saint Gobain India Private Limited (Madras High Court) In the present cases, the Financial Year is 2015-16 and the assessment year is 2016-17. The period of 21 months would commence on 31.03.2017, the assessment year ended on 31.12.2018 normally and the extended period would end on 31.12.2019 and not on 01.01.2020. The contention […]
Tokai Rika Minda India Private Limited Vs DCIT (ITAT Bangalore) On the issue of Transfer Pricing (TP) adjustment to be restricted to AE transactions, we find that the Assessee has rightly contended that section 92 of the Act can be applied only in respect of international transactions i.e., transactions with AE. The ITAT in the […]
Hon’ble Bombay HC, in the case of DIT v/s Besix Kier Dabhol, has held that the Revenue has no power to re-characterize a transaction entered into by the Assessee. Therefore admittedly, the AO or the TPO are not empowered to convert and re-characterize a transaction of share application into a loan transaction.
As you are aware that, it is duty of every citizen whether human or corporate to pay applicable taxes levied by Government of India. These taxes are necessary for development and social welfare of the citizens. Government of each country depends on taxes paid by their citizens and formulate its expenditure for welfare, hospitality, social […]
Lenovo (India) Pvt. Ltd. Vs DCIT (ITAT Banagalore) Ld. TPO thus applied the TNMM as the MAM and determined ALP which resulted in adjustment of Rs. 10,19,77,372/- to the Manufacturing Segment. The assessee filed objection before the DRP agains the proposed adjustment. However the DRP upheld the order of Ld. TPO by observing that in […]
Honda Cars India Ltd. Vs DCIT (ITAT Delhi) In this case In spite of intimation to the TPO and the Assessing Officer regarding the amalgamation of ‘Honda Motor India Pvt. Ltd.’ to ‘Honda Cars India Ltd.’, not only the order under section 92CA(3) of the Act was passed in the name of the amalgamated company, […]
ITAT held that when Indian A.E. is remunerated at arm’s length price (ALP) no further profit attribution is required and the issue of existence of P.E. becomes wholly tax neutral.
