Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...
Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...
Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...
Income Tax : CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing cla...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : It was held that transactions and FAR of assessee were similar to AY 2021-22 and as per the records brought to our notice, there...
Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...
Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...
Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...
Income Tax : CBDT sets 1% tolerance for wholesale trading and 3% for other cases under Section 92C for FY 2024-25. No adverse effects from retr...
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...
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.
If a company is having huge asset base, brand value, goodwill and presence in global market with significant R & D, then it cannot be compared with a company which is purely captive service provider in ITeS/BPO, having low risk and insignificant assets.
Tax havens create huge challenges before countries in terms of shifting of profits, flight of capital, hiding of unaccounted wealth & other assets of tax residents of countries and providing a safe haven for parking corruption proceeds from where it is ultimately laundered back into source countries.
Two issues are important for determining the arm’s length price of the services provided to foreign affiliate by an Indian service provider. These are proper determination of cost base on which arm’s lengthy mark- up will apply and the mark-up. The article deals with the issue of constituents of cost base. Hopefully, the proper determination of cost base by the assessee and in the transfer pricing audit will help in collection of due taxes in India.
In order to overcome the issue of double taxation, the concept of Permanent Establishment (PE) was introduced. Taking a step back into the first treaty on double taxation, the provision provides that business profits made by a PE were to be taxed in the country where the PE is situated.
Transfer Pricing: Suggested Operating Profit Margins for IT and ITeS Sector having Turnover between Rs. 50 lakhs to Rs. 50 crores This is high time for the entities which have to comply with the provisions of Transfer Pricing (TP) under Income-tax Act, 1961 (the Act) i.e. only 5 days left for filing of the various […]
The Finance Act, 2016 introduced provisions relating to Country by Country Report (CbCR) and Master File pursuant to adoption of OECD’s BEPS Action Plan-13 in India. On 31st October 2017, CBDT released the Final Rules with respect to maintenance and furnishing of Master File and CbCR. Summary of Final Forms and Rules for Master-File applicable […]
