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Formal Transfer pricing regulation has been present in India for more than twelve years. Section 92 of income tax act, 1961 warrants that international transactions between the associated enterprises shall be computed having regard to the Arm’s Length Price (ALP).
We also note that the Delhi High Court in Commissioner of Income Tax Vs. Keihin Panalfa Ltd. (ITA No.11 of 2015) decided on 9th September, 2015 has while dealing with transfer pricing adjustment in the absence of segmental accounts held that adjustments have to be restricted only to transactions with Associated Enterprises. It further held that whereseparate accounts are not available, then proportionate adjustments to be made only in respect of the international transactions with Associated Enterprises.
Rule. Mrs. Mauna N. Bhatt, learned advocate waives service of notice of rule on behalf of the respondents. In the facts and circumstances of the case and with the consent of the learned advocates appearing for the respective parties, the present petition is taken up for final hearing today.
Anomaly between the provision of Finance Bill and Memorandum explaining the Finance Bill- Interestingly the phraseology used in Memorandum explaining the provisions of The Finance Bill 2017 and Finance Bill 2017 to calculate the excess interest is ambiguous and results in different outcome.
Finance Act, 2012 has made an amendment to extend the Transfer Pricing Provisions to the transactions entered with domestic related parties or by an undertaking with other undertakings of the same entity for the purposes of section 40A, chapter VI-A and section 10AA.
Budget 2017- it is proposed to provide that expenditure in respect of which payment has been made by the assessee to a person referred to in under section 40A(2)(b) are to be excluded from the scope of section 92BA of the Act. Accordingly, it is also proposed to make a consequential amendment in section 40(A)(2)(b) of the Act.
Country’s tax administrations often introduce rules that place a limit on the amount of interest that can be deducted in computing a company’s profit for tax purposes. Such rules are designed to counter cross-border shifting of profit through excessive interest payments, and thus aim to protect a country’s tax base.
Hon’ble Supereme Court admits SLP- Transer pricing adjustment should be restriced to AE transactions only and not on entire turnover of assessee
Business restructuring refers to the cross-border re-organisation of the commercial or financial relations between associated enterprises, including the termination or substantial renegotiation of existing arrangements.
To calculate an effective royalty rate for a comparison with a third party royalty rate, one may have to not only determine what will be the future economic benefit that may arise in the form of cash flows but also convert them into a rate (say as a percentage of sales).
