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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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...
Axis Risk Consulting Services Private Limited. Vs DCIT (ITAT Delhi) the only dispute before us is with regard to the adjustment by way of imputing interest @ 17.22% by the TPO on account of receivables from the AE. Here in this case, it is an undisputed fact that the assessee has also rendered similar services […]
The revised SHRs apply for AY 2017-18 and two immediately following AYs i.e. upto AY 2019-20. The earlier SHRs were applicable from AY 2013-14 and four immediately following AYs i.e. upto AY 2017-18. For AY 2017-18, the taxpayer can choose from old or new rules whichever are more beneficial.
Marketing activities undertaken by one enterprise not owning the trademark or brand name lead to the creation of marketing intangibles for the legal owner of such trademark or brand name. Indian enterprises having the right to use the brand name owned by their associated enterprises incurs the advertisement, marketing and promotional expenses (AMP Expenses) to get the benefit in the form of increased sales, higher profit etc. This in turns benefit the legal owner of the brand name i.e. associated enterprises.
Attached PPT Cover Following Topics related to Transfer Pricing : Basic Provisions, Issues and Latest Developments- ♥ Introduction to Transfer Pricing ♥ Transfer Pricing Regulations in India – Sec.92 to 92F ♥ Analysis of word “Income” as mentioned in Sec.92 ♥ AE & Deemed AE [Interplay between Sec.92A(1) & 92A(2)] ♥ International Transaction – Sec.92B […]
Hon’ble ITAT upheld the position of law as iterated by CIT (A) that it is an established law applicable for imposition of penalty that law, as in force, at the time of filing of Return would be applicable.
Margins derived on export of parts to AE are not comparable with the margins derived from sales made in the domestic market. Besides, on facts, it was also found that not only the parts and finished goods are not comparable, but the class of customers to whom they sold is also different.
Mehsana District Co-operative Vs. DCIT (Gujarat High Court) Subrule (7) of rule 10THD thus lays down the time limit for the Assessing Officer to pass an order under subrule(4) and for the concerned competent authority to pass an appropriate order under subrule(6). We may recall under subrule(4), the Assessing Officer may declare that the option […]
It is worthwhile to note that there are marked similarities between the Transfer pricing and Customs regulations in terms of the methodology to arrive at the relevant transfer price. For instance, the deductive method under Customs law can be correlated to the resale price method under Transfer Pricing law.
The Indian Central Board of Direct Taxes (CBDT) has notified the final rules (the rules) for maintaining and furnishing of Transfer Pricing (TP) documentation in the Master File (MF) and Country-by-Country Report (CbCR). Following an inclusive approach when introducing a new and important regulation, the CBDT had
Transfer pricing (TP) regulations have been at the forefront of corporate headlines over the last few years due to the increasing number of controversies resulting out of tax structuring by multinational companies (MNE). What makes the topic both contentious and interesting is that regulators view the various techniques applied to intercorporate transactions as purportedly planned with the intent of achieving benefits of comparable labor cost and tax advantage at the cost of a countries tax revenues.
