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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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...
Once the existence of dependent agency permanent establishment was wholly tax-neutral, unless it was shown that the agent had not been paid an arm’s length remuneration, and when it was not the case of AO that the agents had not been paid an arm’s length remuneration, the question regarding the existence of dependent agency permanent establishment, i.e., under article 5(4), was a wholly academic question.
DCIT Vs Knorr Bremse India Pvt. Ltd. (ITAT Delhi) TNMM is the Most Appropriate Method to benchmark the international transactions entered into by the taxpayer with its AE qua professional consultancy services (information technology) and fee for management support services but TPO, for the reasons best known to him and to our mind to generate […]
Lam Research (India) Pvt. Ltd. Vs DCIT (ITAT Bangalore) It was submitted that Working capital adjustment is made for the time value of money lost when credit time is given to the customers. The Assessee however does not bear any risk and has no working capital contingencies. The Assessee has not incurred any expenses for […]
ADIT Vs Asia Today Limited (ITAT Mumbai) It has not been the case of the revenue authorities at any stage that the remuneration paid to the Indian agent is not an arm’s length remuneration for the services rendered by the agents concerned, yet a prayer is now made that the matter should be sent back […]
Rayban Sun Optics India Ltd. Vs ACIT (ITAT Delhi) We are of the considered opinion that the ALP of an international transaction involving AMP expenses, the adjustment made by the TPO/DRP/AO is not sustainable in the eyes of law. At the same time, we cannot ignore the submission of the learned DR that the matter […]
PCIT Vs Novell Software Development (India) Pvt. Ltd. (Karnataka High Court) Facts: 1. Taxpayer, a captive software development and support service provider, is subsidiary of Novell Inc US. The taxpayer provided software development and support services to its US Associated Enterprise and adopted Transactional Net Margin Method. 2. The taxpayer was providing depreciation as per […]
The Dehradun Chartered Accountants Society Vs. Union of India (High Court of Uttarakhand at Nainital) High Court held that Admittedly, the country continues to suffer and to reel under the COVID-19 pandemic. A large number of assesses still find it difficult to even meet their Chartered Accountants and to file their Income Tax Audit Reports […]
High Court (HC) declined to interfere in the matter of extension of the due date for filing Tax Audit Report (TAR) and Income Tax Return (ITR) The Hon’ble Gujarat High Court in All Gujarat Federation of Tax Consultants v. Union of India [R/Special Civil Application No. 13653 and 660 of 2021, dated January 13, 2021] […]
Government is neither listening to representations submitted by various associations, nor listening to court direction in true spirit. In Covid 19 pandemic, all professionals and Trade, ignoring life and death risk, ensured that, India will stand again, paid taxes in lakh crores but it seems government doesn’t recognize us.
At this stage, we may only observe that the CBDT may consider issuing an appropriate circular taking a lenient view as regards the consequences of late filing of the Tax Audit Reports as provided under Section 271B of the Act. We leave it to the better discretion of the CBDT in this regard.
