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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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...
Arbitration and specifically Last Best Offer Arbitration, has historically been used to resolve disputes between unions and management and is best known for resolving compensation disputes between Major League Baseball teams and their players, hence the name Baseball Arbitration.
Transfer pricing transaction in a MNE is done to reduce tax burden and improve profits of the enterprise. It is usually done by utilizing the complex economic to their advantage globally. A MNE would transfer its profits form high tax jurisdiction to associated enterprise in a low tax jurisdiction.
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 […]
