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It is seen that the company has completed full-length animated commercial film during the year under consideration. We note that no separate revenue and expenditure on this activity of making animated film is reported in the Annual Report. Since the activity of making animated film is functionally different from the activity of software development services and thus the segment of ‘software development and services’ of the company, cannot be compared with the functions of the assessee.
With respect to opening WDV in case of the foreign company whose PoEM is determined in India and which is assessed to tax in the home jurisdiction, the final notification provides for 2 cases:
Production loss depends on number of factors and in absence of any comparable to show that loss shown by the assessee is excessive, the contention of the assessee has to be accepted
The CBDT has issued the Final Notification No. 29/2018 dated 22 June 2018 (applicable from AY 2017-18) for exception, modification and adaptation in respect of a foreign company said to be resident in India due to its place of effective management (POEM) being in India, under Section 115JH of the Income-tax Act, 1961 (the Act). […]
Draft Notification of exception, modification and adaptation in respect of foreign company said to be resident in India under section 115JH of the Act The Central Board of Direct Taxes (CBDT) on June 15, 2017 issued a Draft Notification (notification) vide F No. 370142/19/2017-TPL for exception, modification and adaptation in respect of foreign company said […]
In transfer pricing disputes, comparability analysis and use of appropriate filters has been one of the most prevalent issues, especially for captive cost plus remuneration service providers.
Amendment in Rule 10CB of Income-tax Rules, 1962 in respect of computation of interest income pursuant to secondary adjustment made under section 92CE of Income-tax Act, 1961 – Comments and suggestions
Whether the Indian subsidiary of the assessee constitutes Permanent Establishment (PE) of the assessee in India on account of ‘signing, networking, planning and negotiation of offshore supply contracts in India’? If yes, whether any profit is attributable to the same, and the quantum thereof?
Adjustment on account of arm’s length price (ALP) of international transaction is restricted only to the extent of international transaction with associated enterprises (AE).
Mitchell Drilling India Private Limited vs. DCIT (ITAT Delhi) It is elementary that the ALP is determined of an `international transaction’, which has been defined in section 92B of the Act. The term `transaction’, for the purposes of the Chapter–X containing transfer pricing provisions, has been defined in clause (v) of section 92F to include an […]
