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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...
In the recent landmark judgement of Texport Overseas Private Limited v. DCIT [IT(TP)A No. 1722/Bang/2017], Honorable Bangalore Tribunal held that: it would be deemed that clause (i) of Section 92BA of the Income-tax Act, 1961 (‘the Act”) was never been on the statute as it has been omitted w.e.f. April 01, 2017 vide Finance Act, 2017 and nothing was specified whether the proceeding initiated or action taken on this continue.
Whether the observations of Honble DRP is right in directing the TPO to give working capital adjustment [using OCED methodology given in Annexure to chapter – 3 and applying SBI Prime Lending Rate (as on 30th June of the relevant financial year) as the interest rate] against the TPO order dated 16.01.2014 passed u/s 92CA(3) for A.Y. 2010-11.
Since, the determination of arm’s length price in the appeal effect order has not lead to any transfer pricing adjustment, with no effect on income of the assessee, hence, penalty provisions are not applicable in this case, therefore, we cancel the orders of the authorities below thereby deleting the penalty in dispute.
Whether the omission of reference of section 40A(2)(b) from section 92BA by virtue of the amendment of Finance Act, 2017 w.e.f. 01.04.2017 shall be deemed not to be on the statute since its introduction w.e.f. 01.04.2012?
Pursuant to the amendment made by Finance Act 2017, omission of clause (i) of Section 92BA of the IT Act, 1961 be deemed to be removed from statute since the beginning until and unless there is some saving clause or provision that pending proceedings shall be continued and be disposed off under old rules.
ITAT Delhi, last week held that the transaction of making payment of Rs. 95,50,31,150/- (on account of arbitral award) by Hyundai Rotem Company to the DMRC made on behalf of its AE would not part of the margin calculation to be added to revenue and cost for bench marking the international transaction.
A division bench of the Delhi ITAT, last week held that penalty under section 271(1)(c) of the Income Tax Act, 1961 cannot be levied if the Arm’s Length Price (ALP) was determined as per the scheme of section 92C in good faith and with due diligence.
Pr. CIT Vs Makemy Trip India Pvt. Ltd. (Delhi High Court) The Court is of the opinion that no substantial question of law arises. The difference of opinion between the CIT(A) and the TPO, as to the appropriateness of one or the other methods, cannot per se be a ground for interference; the appropriateness of […]
ITAT Bengaluru held in the case of Nuance Transcription Services India (P.) Ltd. v Dy. CIT that Outstanding Receivables from AE is an international transaction as per Explanation to Section 92B inserted by the Finance Act 2012 and non-charging of interest for a period exceeding 6 months requires ALP adjustment.
Clarification of India’s position on the acceptance of MAP and bilateral APA in cases of countries where Article 9(2) of OECD Model Tax Commentary is absent