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ITAT Delhi held that as to whether a transaction is entered into at an Arm’s Length Price or not must depend upon the facts of each case relating to the transaction per-se i.e. the transaction itself as the profit is only a possibility of the desired result with or without the aid of international transaction.
Section 92CA(1) does not contemplate that the assessing officer has to first come to a definite finding that there is an international transaction within the meaning of Sec. 92B before he can exercise his power to refer the matter to the TPO.
These appeals raise an interesting issue with respect to interplay of Article 9 of India Netherlands Double Taxation Avoidance Agreement and TP adjustments under domestic TP law.
CUP (Comparable Uncontrolled Price Method-Applicability : When similar an uncontrolled transaction is available. Where all the term of contract are identical for both, domestic and uncontrolled transaction or otherwise the differences are quantifiable and can be adjusted
The assessee did not benchmark the royalty payment separately. On enquiry by the TPO, it relied on RBI approval given in 1995 and also on the fact that the assessee earned a gross profit of 41.6%. TPO applied Press Note 9 (2000 series) and restricted it to 1% on the plea that the payment was for use of trademark without transfer of technology.
The results of a recently conducted global survey of 2,600 businesses in 36 countries, finds little impact from the OECD BEPS programme which was finalised last October, as 78 percent of the surveyed businesses said that they have not changed their businesses approach to taxation, despite more than 80 countries having agreed to adopt at least the minimum elements of the BEPS Action Plan.
Aggregation of transactions or ‘Combined Transaction Approach’ is a well-accepted practice for benchmarking and determination of Arms’ Length Price of international transaction/ specified domestic transactions in Transfer Pricing Certification and assessments and is widely upheld in many judgements.
The treatment of extended credit period to Associated Enterprises(AEs) as an international transaction and making adjustment of notional interest on the same has always been bone of contention between the assessee and department.
In this article we will explain about the provisions relating to penalty for failure to keep and maintain documents in respect of specified domestic transactions. However, before understanding the penalty provisions, one should have an overview of the basic provisions of transfer pricing in relation to specified domestic transactions.
The critical question before special bench: Whether, on the facts and in the circumstances of the case, no arm’s length rate of interest was required to be charged on the loan granted by the non-resident assessee-company to its wholly owned subsidiary Indian company M/s. Datex-Ohmeda (India) Pvt. Ltd. (Datex)?
