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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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...
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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...
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Transfer Pricing Compliance Chart for Financial Year 2019-20 which includes Transfer Pricing Audit, Transfer Pricing Study- Documentation, Return of Income (Having applicability of Transfer Pricing Provisions), Master File, Intimation by a designated Constituent Entity, Intimation by Designated Constituent Entity and CbCR. Activity Section / Rule Form No. Old Deadline New Deadline Remarks Transfer Pricing Audit […]
PCIT Vs. Gulbrandsen Chemicals Pvt. Ltd. (Gujarat High Court) The Tribunal has taken into consideration the voluminous documentary evidence on record for the purpose of coming to the conclusion of adoption of TNMM by the assessee as the Most Appropriate Method of arriving at ALP. The Delhi High Court in the case of Make My […]
The Hon’ble Finance Minister, Ms. Nirmala Sitharaman, presented the Union Budget on 1 February 2020, introducing measures aimed at, inter-alia, reducing litigation, improving effectiveness of tax administration, providing tax certainty and simplifying compliance with the overall objective of enhancing the ease of doing business in India. This article focuses on key proposals relating to Indian […]
ITATheld that the ad hoc determination of ALP de-hors Section 92C of the Act cannot be sustained, rendering the entire transfer pricing adjustment unsustainable in law.
Key Highlights of Transfer Pricing Proposal in Union Budget 2020-21: > As per amended provisions, Form 3CEB filing date is 31st October 2020 for FY 2019-20. > Dispute Resolution Panel forum is now not limited to Transfer Pricing disputes only but also allowed to non residents for all disputes. > Provisions of interest limitation (Section […]
It can be fairly concluded from the above judicial pronouncements that the receivable mentioned in the Explanation to Sec.92B can be taken up for transfer pricing scrutiny only when it is a standalone activity or a demonstrated approach is adopted by the assessee to use Accounts Receivable to have free working capital funding.
Swastik Coal Corporation Pvt. Ltd. Vs Pr. CIT (ITAT Indore) The basis of exercising of revisionary jurisdiction u/s 263 of the Act as per Ld. Pr. CIT is that transfer pricing related issues were not examined by the A.O. since the transaction carried out by the assessee are covered under specific domestic transactions. The contention […]
Finance Act, 2017 inserted a new Section 92CE in the Income-tax Act, 1961 with effect from 1st day of April, 2018 to provide for secondary adjustment by attributing income to the excess money lying in the hands of the associated enterprise.
The CBDT has released the final rules through notification (N No. 3497(E) on preparation and filing of Master file by the Constituent Entity of an International group. The brief of the rules as notified and the documentation requirements as needed for the filing are summarized below:
The Central Board of Direct Taxes (CBDT), has released the final rules through a notification (N No. 3497(E) on preparation and filing of Master file by the Indian Entity of an International group. The brief of the rules as notified and the documentation/information requirements as needed for the filing are summarized herewith for your reference.
