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 : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...
Income Tax : Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Underta...
Income Tax : Delve into the complexities of digital taxation, exploring its evolution, significance, and global responses. Learn about fair ta...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : 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 : Tribunal upholds CIT(A) decisions in DCIT Vs Astral Limited case, offering key insights on TP adjustments, ESOP expenses, and Sect...
Income Tax : Delhi High Court quashes reassessment notices by DCIT after TPO settles arm's length remuneration issue. Detailed analysis of Prog...
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 ITAT Delhi’s ruling in American Express India vs DCIT. Key issues: Comparable selection, transfer pricing adjustments, corporate tax matters.
Expenditure incurred on Advertisement, Marketing and Promotion (AMP) for creating market intangibles including brand value in favour of Associated Enterprises was not considered as an international transaction as mere use of brand name or logo owned by the AEs by assessee would not automatically lead to influence that any expenses that assessee incurred towards AMP was only to enhance the brand and there was no cogent material to treat the incurring of AMP expenses as international transactions.
Draft Format of Form 3CEB for AY 2020-21 amended vide Notification No. 82/2020 dated 1st October, 2020 in Excel /Word Format As Form No. 3CEB (Transfer Pricing Audit Report) has been amended recently vide Notification No. 82/2020 dated 1st October, 2020. However, the utility is yet to be updated. So, sharing the updated draft of […]
1. The Rajasthan Tax Consultants Association vs. Union of India (Rajasthan High Court), D.B. Civil Writ Petition No. 12605/2020 As per sources The Rajasthan Tax Consultants Association has filed a writ with Hon’ble Rajasthan High Court on 19.10.2020 which got registered on 21.10.2020 for Granting extension of Tax Audit due date for AY 2020-21. The […]
Request for Extension of due date for filing of Tax Audit reports, Transfer Pricing (TP) Audits and Income-tax returns-AY 2020-21 till 31st March 2021.
Many countries limit the amount of interest expenses of multinational companies (MNC). An enterprise who has borrowed capital in form of loan from its associate enterprises can claim deduction of interest paid and payable to associated enterprises. Foreign companies have several models to infuse capital in its associated company situated in another country. Some may […]
Notification No. 83/2020-Income Tax Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C of the said Act and the price at which the international transaction or specified domestic transaction has actually been undertaken does not exceed one per cent. of the latter in respect of wholesale trading and three per cent. of the latter in all other cases, the price at which the international transaction or specified domestic transaction has actually been undertaken shall be deemed to be the arm’s length price for assessment year 2020-2021.
M/s. Blue Yonder India Private Limited, (Formerly JDA Software India Private Limited) Vs DCIT (ITAT Bangalore) E-INFOCHIPS LIMITED- The Annual Report of e-Zest Solutions Limited for assessment year 2010-2011 (placed at page 527 to 534 of the paper book) clearly demonstrates that it is engaged in end to end product development, including product design and […]
DCIT Vs Convergys Customer Management Group Inc. (ITAT Delhi) It is mandatory for all taxpayers, without exception, to obtain an independent accountant’s report in respect of all international transactions between associated enterprises or specified domestic transactions. The report has to be furnished by the due date of the tax return filing. Even if it is […]
Bank of India Vs JCIT (ITAT Mumbai) Conclusion: PCIT rightly directed Bank of India’s case to TPO for determination of arm’s length price (ALP) in relation to international transactions and specified domestic transactions under revision proceedings as it was binding on AO as per the CBDT Circular in force at that point of time under […]
