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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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...
Hyundai Construction Equipment India Private Ltd. Vs ACIT (ITAT Pune) Ground no.8 of the appeal is against making transfer pricing adjustment on entity level rather than restricting it to the AE transactions. The TPO computed the transfer pricing addition by considering revenues from Manufacturing segment‘ in totality at the entity level The DRP did not […]
TPO determined ALP on the combined accounts approach rather than the split approach adopted by assessee as assessee failed to substantiate such common material costs were properly allocated segment-wise and Transfer Pricing Adjustment made at entity level should be restricted to international transactions only.
Section 92 of the Income Tax Act deals with any income or expense arising from an ‘International Transaction’. In order to understand the definition of ‘International Transaction’, it is essential to understand the definition of ‘Transaction’. Clause (v) of Sections 92F of the Act defines a transaction as: Section 92F of the Act provides an […]
Organization for Economic Cooperation and Development (OECD) and the (G20) countries have launched an initiative known as base erosion and profit shifting (BEPS), which consists mostly of tax avoidance methods. These techniques primarily aim to fill in and make accommodations for tax policy loopholes, which aid in leveraging such gaps in tax regulations to deceptively shift earnings to low or no-tax nations. A business is often funded (or capitalized) through a combination of debt and equity.
everting to the CUP method applied by assessee as the most appropriate method for benchmarking the SDT of rent payment, assessee had given a comparable instance of rent paid @ Rs.112 per sq.ft. by ICICI bank under a lease agreement dated 17.02.2012 for a nearby premises. As against that, the assessee paid rent @ Rs.75.28 per sq.ft., which showed that the rent paid by assessee was less in comparison with the comparable uncontrolled transaction. Thus, the ALP of the Specified Domestic Tranasction of payment of rent could not be disputed.
The litigation in taxation matters is increasing on a rapid scale. However, where the transactions involves the foreign companies or their subsidiaries it is governed under the head of transfer pricing. The increasing participation of multi-national group in economic activities in the country has given rise to new and complex issues emerging from transactions entered in to between two or more enterprises belonging to the same multi- national group.
Honda Motorcycle & Scooter India Pvt. Ltd Vs DCIT (ITAT Delhi) With respect to the TP adjustment to the export commission, which is claimed by the assessee that it is intrinsically, looked that the main activity of manufacturing and sale of products and as such could not be identified separately for benchmarking. It is also […]
Dow Agrosciences India Private Limited Vs ACIT (ITAT Mumbai) We shall now deal with the observation of the TPO/DRP that the approval provided by the RBI would not constitute a valid CUP data, since the RBI does not take into account the transfer pricing provisions to determine the appropriate rates which can be considered as […]
Since in the financial statement for the relevant year (F.Y. 11-12), the auditor had made a clear disclosure that no revenue had been recognized on account of services rendered to SBI despite having incurred a cost of Rs. 3.2 crore and moreover, as per the matching ‘principl
The Indian Transfer Pricing Regulations (i.e. Section 92C of the Income-tax Act, 1961 read with Rule 10B of the Income-tax Rules, 1962) as well as the OECD Transfer Pricing Guidelines provide the following 5 common transfer pricing methods for evaluating the related party transactions undertaken between entities: 1. Comparable Uncontrolled Price (CUP) Method – The […]
