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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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...
M/s. CLSA India Private Limited Vs DCIT (ITAT Mumbai) Facts of the case: The assessee company, i.e. CLSA India Private Limited is a subsidiary of Credit Lyonnais Securities Asia (CLSA) incorporated in Netherlands. The assessee is primarily engaged in the business of equity broking. The assessee’s customers comprise of foreign institutional investors (FIIs) and domestic […]
Anurag Agrawal Introduction Over several decades and in step with the globalisation of the economy, intra group transactions have grown exponentially world-wide especially related to intangible assets. The word “intangible asset” is intended to address something which is not a physical asset or a financial asset, which is capable of being owned or controlled for […]
Sony Pictures Networks India appeal: By not dealing with an issue which is otherwise ripe for consideration and instead remanding to the TPO, the Tribunal ensures further litigation and continued uncertainty for both the Revenue and the assessee, non-consideration of the basic submission made at the hearing as recorded, is clearly a mistake apparent from the record
ITAT came to a finding that Motilal Oswal Investments Advisory Pvt. Ltd. was not a concern which could be included in the list of comparable companies. We do not think that these findings of fact are in any way perverse or vitiated by any error apparent on the face of the record which, in turn, would give rise to any substantial question of law.
In the aftermath of the second world war, the global trade has continued to develop and has resulted in globalization of trade. In the era of globalization, the fixed boundaries within which a firm used to operate have transcended and firms have integrated their operations around the world, taking advantage of cheap labour and technological […]
Transfer pricing provisions seek to ensure that there is fair and equitable allocation of taxable profits amongst the tax jurisdictions. In cases where the underlying transaction is held not to be at arm’s length, a primary adjustment is made to align the transfer price with the arm’s length price (ALP) which is known as primary […]
Nivea India Pvt. Ltd Vs ACIT (ITAT Mumbai) TPO had not brought on record the fact that AMP expenses incurred by assessee were not for its own business. The sole basis on which adjustment, under the head AMP expenditure, was made was that expenditure incurred by assessee was significantly higher than that of its comparable […]
Pr. CIT Vs M/s TIBCO Software (India) Pvt Ltd (Bombay High Court) Any inclusion or exclusion of comparables per se cannot be treated as a question of law unless it is demonstrated to the Court that the Tribunal or any other lower authority took into account irrelevant consideration or excluded relevant factors in the ALP […]
The Finance Act, 2012 expanded the scope of the term International Transaction thereby giving the clarity as to what the legislature meant or rather deemed fit to be International Transaction and consequential amendments were also made to other connected sections of Transfer Pricing in the Income-tax Act, 1961.
After the grand success of International Transfer pricing, through which huge transfer pricing orders slapped on companies with cross-border operations in the financial year 2011-12, Hon’ble Finance Minister has cast his net wider and deeper for the next one by including Specified Domestic Transactions in the purview of Transfer Pricing (TP).
