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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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...
CBDT amends Rule 10CB relating to interest income computation for secondary adjustments (Notification No. 76/2019/ F.No.370142/12/2017-TPL) Introduction The Finance Act, 2017 inserted Section 92CE in the Income-tax Act, 1961 (the Act) w.e.f. 1 April, 2018 to provide for secondary adjustment, where, as a result of primary adjustment to the transfer price, there is an increase […]
CBDT Amends Income Tax Rule 10CB -Computation of interest income pursuant to secondary adjustments vide Notification No. 76/2019-Income-tax dated 30th September, 2019. MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) New Delhi, the 30th September, 2019 Notification No. 76/2019-Income-tax G.S.R. 701(E).—In exercise of the powers conferred by sub-section (2) of section 92CE […]
In our recent discussions, we had come across that many of the business people and few of the professionals were not aware/familiar with the Transfer Pricing (TP) provisions and the related compliances. This document is intended to provide the basic knowledge of the same.
Base Erosion Profit Shifting (‘BEPS’) Action Plan Weakness of international tax system created several opportunities for tax payers for shifting profits to tax friendly jurisdictions. To create transparency, exchange of information and to avoid treaty abuse, G20 leaders endorsed BEPS Action Plan and developed the same with Organisation of Economic Co-operation and Development (‘OECD’). BEPS […]
Notification No. 64/2019- Income Tax provides for tolerance range of one per cent. for wholesale trading and three per cent. in all other cases for assessment year 2019-20. It is certified that none will be adversely affected by the retrospective effect being given to the notification. MINISTRY OF FINANCE (Department of Revenue) New Delhi Notification […]
Times Global Broadcasting Company Ltd Vs Union of India & Ors. (Bombay High Court) It is indisputable that by virtue of sub-sections (2A) and (2B) of Section 92CA, in case of an international transaction, the TPO would have an authority to examine any international transaction which comes to his notice during the proceedings, whether a […]
In view of the guidelines issued by the CBDT in Instruction 3/2003 the Tribunal was right in observing that by not making reference to the TPO, the Assessing Officer had breached the mandatory instructions issued by the CBDT.
M/s. Barco Electronic Systems (P.) Ltd. Vs. DCIT (ITAT Delhi) Facts of the Case ♣ Barco Electronic Systems Pvt. Ltd. ( taxpayer) is engaged in business of manufacturing of projectors and parts, trading in visual display products and provision of software development services. ♣ During the year under consideration, the taxpayer entered into various international […]
Download comprehensive cases summary of Captive Service Providers- January 2019 to July 2019 from the link given below-
Bright line test is not an appropriate yardstick for determining existence of an international transaction for calculating arms length price.
