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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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...
Explore the issue of mandatory binding arbitration in India and its critical analysis. Learn about the impact on double taxation avoidance agreements and dispute resolution mechanisms.
The paper will firstly discuss cloud-based TP activities and the challenges to regulate them; secondly, analyse the feasibility of regulating cloud-based TP activities through blockchain smart contracts; and finally, scrutinise the risks of regulating cloud-based TP activities through blockchain-based RegTech and provide possible solutions for the same.
It is settled law that exclusion or inclusion of one or other comparable would by itself not constitute a question of law unless it is shown that there are important functional dissimilarities or vital material facts which go to the root of profitability or where other material circumstances are involved.
B. Braun Medical (India) Private Limited Vs DCIT (ITAT Mumbai) ITAT deletes Transfer Pricing (TP) Adjustment as TPO adopts Wrong Gross Profit (GP) Margin of Comparable Company The assessee raised an additional ground before the Ld. DRP stating that the gross profit margin of ADS Diagnostics Ltd., had been wrongly worked out by the Ld. […]
TPO/AO cannot apply wrong method in the absence of material ie: audited financials of AE. More so, TPO/AO cannot even give the benefit as well to assessee for non cooperation for providing the audited financials of AE.
In India, the underlying idea behind the scheme of APA is to make tax administration better and efficient by encouraging taxpayers to provide all the data essential for a comprehensive transfer pricing analysis and to motivate them towards engaging a mutual agreement.
The APA determines the transfer pricing methodology for pricing an enterprises’ future international transactions or certain specified domestic transactions.
The last few decades have witnessed significant globalization, which has led to the drastic growth of international transactions between parties situated in different nations. However, with this vast geographical network of transactions, comes the problem of keeping up with the different tax rates at which different countries operate.
Multinational entities (MNEs) have actively contributed to the global value chain. These MNEs that have established affiliates or subsidiary companies transacting cross-borders and have always been a matter of discourse. Such related party transactions if ungoverned, tend to create a hassle for their respective jurisdictions in allocating taxing rights and could lead to an administrative tax tangle.
It is highly essential for multinational enterprises to come up with different workable business strategies to compete in today’s economy. One such strategy is business restructuring. Business restructuring is an activity wherein companies significantly modify their financial and operational aspects of a company.
