Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...
Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...
Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...
Income Tax : CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing cla...
Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : It was held that transactions and FAR of assessee were similar to AY 2021-22 and as per the records brought to our notice, there...
Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...
Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...
Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...
Income Tax : CBDT sets 1% tolerance for wholesale trading and 3% for other cases under Section 92C for FY 2024-25. No adverse effects from retr...
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...
The ITAT Mumbai in the above cited case held that Advertising, Promotion and Marketing expenses (AMP) cannot be considered as international transaction unless there exist an agreement between the assessee and its AE to share/reimburse the AMP expenditure incurred by the assessee in India.
Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the price at which the international transaction or specified domestic transaction has actually been undertaken does not exceed one percent of the latter in respect of wholesale trading and three percent.of the latter in all other cases
In case, the owner of a brand name allows its usage to another entity, then a fee is recovered as a mode of compensation which is generally known as brand royalty.
Assessee had provided a corporate guarantee on behalf of its associated enterprise M/s. Thomas Cook Mauritius Operations Co. Ltd. for banking facilities availed by it from HSBC bank to the extent of Rs.6,01,80,000/-.
An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it carries on business in that other State through a broker, general commission agent, or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business.
In the recent past, Central Board of Direct Taxes (CBDT) has issued an instruction No. 3/2016 (Instruction) in perspective of the international transaction or specified domestic transactionto be referred by the Assessing Officer (AO) to Transfer Pricing Officer (TPO). The instruction ushered new guidelines for implementation of Transfer Pricing Provisions for referring international transactions or specified domestic transaction to the TPO subject to the approval of jurisdictional Principal Commissioner of Income Tax (PCIT) / Commissioner of Income Tax (CIT).
OECD stands for Organization for Economic Co-operation and Development. It is an international organization comprising of 34 countries with an objective to stimulate economic progress and world trade. The organization actively conducts researches in various areas of taxation and economic development based on which it issues recommendations to its member countries.
11/5/2016 – OECD countries agreed today to invite Latvia to become a member of the Organisation – a move that would extend OECD’s membership to 35 countries. OECD Secretary-General, Angel Gurría Said: “We are very pleased to welcome Latvia as a member of the OECD. This development reaffirms our Organisation’s commitment to bring together countries who […]
F.No. P-328/T&P/DC-ACsIT/2016-17/1818 OFFICE OF THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX NEW DELHI Dated : 11th May, 2016 ORDER NO. 38/G.O. 2016-17 Sub:-Estt. Group ‘A’ – Transfers and Postings of Deputy/Assistant Commissioners of Income-tax – Reg. – The transfers and postings of the following Deputy/Assistant Commissioners of Income-tax are hereby ordered with immediate effect and […]
The objective of the BEPS Project is to close gaps in international tax rules, effectively eliminating or substantially reducing BEPS; and to secure government revenues by ensuring that profits are taxed in the jurisdiction where the economic activities generating such profits are performed and where value is created.
