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Notification No. 83/2015 – Income Tax In exercise of the powers conferred by section 92C read with section 295 of the Income-tax Act, 1961 (43 of 1961), the Central Board of Direct Taxes hereby makes the following rules further to amend the Income-tax Rules, 1962, namely:- 1. (1) These rules may be called the Income-tax (16th Amendment), Rules, 2015.
Instruction No. 15/2015 The provisions relating to transfer pricing are contained in Sections 92 to 92F of the Income-tax Act (hereinafter referred to as ‘the Act’). These provisions came into force w.e.f. Assessment Year 2002-2003 and have seen a number of amendments over the years, including the insertion of Safe Harbour and Advance Pricing Agreement provisions and the extension of the applicability of transfer pricing provisions to Specified Domestic Transactions.
In the case of Allscripts (India) Private Ltd.vs. Dy. Commissioner of Income Tax, ITAT Ahemdabad held that for the purpose of find our comparable companies for transfer pricing, companies with very high operating margin can’t be selected as comparable companies without justification/investigation by AO
ITAT Pune held In the case of M/s. Vishay Components India Pvt. Ltd. vs. ACIT that where the revenue from year to year has accepted the method adopted by the assessee for benchmarking its international transactions with its associate enterprises, in the absence of any reasons brought
In case of M/s. AT & T Global Business Services India Pvt.Ltd. VS. ITO , assessee-company, engaged in business of software development and providing application services to its AE. TPO on basis of mean margin earned by his own set of comparables
In the case of Rampgreen Solutions Pvt Ltd vs CIT, Delhi High Court inter-alia held that the expression ‘BPO’ and ‘KPO’ are, plainly, understood in the sense that whereas, BPO does not necessarily involve advanced skills
In the case of Venture Infogain India Pvt. Ltd vs. Dy.Commissioner of Income Tax ITAT has held that provisions the Profit Split Method is applicable mainly in international transactions which are so interrelated that they cannot be evaluated separately
The purpose of a benchmarking study is to select comparable transactions by rationally deriving arm’s length price based on the financial data of selected comparable. On one side the comparables selected by assesses are rejected in many cases particularly of loss making companies and on the other hand high margin comparables are cherry picked and applied.
ITAT Delhi held in the case American Express (India) Private Limited vs. DCIT that even though the assessee in its TP study has included the turnover filter of less than Rs.1 crore, the assessee has given reasons for inclusion of these two companies in the list of comparables
In the case of Price Waterhouse & Anr. Vs CIT, Calcutta High Court through an interim order opined that if there was no relevant material in the hands of the Income Tax authorities with which it has come to an incontrovertible conclusion that the writ petitioner no.1 was an ‘associated enterprise’