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Notification No. 45/2014-Income Tax DATED 23-9-2014 Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the price of 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.
Transfer pricing has become the most significant source of litigation in India and is increasingly becoming a regular discussion point in the board room of large Indian and Global Multinational enterprises (“MNEs”). Indian Tribunals have issued around 650 rulings over the past decade on transfer pricing issues, setting precedents for taxpayers on a wide range of issues.
The Income Tax Act 1961(‘The Act’) as amended by Finance Act 2012 brought specified domestic related party transactions (SDT) within its fold with effect from FY 2012-13 vide section 93BA of the Act and admittedly as with any new legislation, there were very few early adopters. SDT provisions principally have impact in two ways, firstly […]
Once the Assessing Officer is satisfied that a permanent establishment of the petitioner exists in India and business is being conducted from this permanent establishment, the attribution of profits is a necessary consequence.
Assessee has challenged the addition made by the A.O. and sustained by the ld. CIT(A) by way of TP adjustment on account of interest chargeable on the amount of share application money paid to its AE and lying unutilized for a period beyond 60 days treating the same as loan.
The existing provisions of section 92B of the Act define ‘International transaction’ as a transaction in the nature of purchase, sale, lease, provision of services, etc. between two or more associated enterprises, either or both of whom are non-residents. Sub-section (2) of the said section extends the scope of the definition of international transaction by […]
Nilesh Patel – CPA (USA), IRS (Former) Under the Indian Transfer Pricing Regulations (Sec. 92 to Sec. 92F and Sec. 94A of the I.T. Act 1961; and Rules 10A to 10TG of the I.T. Rules 1962) the transactions of intra-group transfers of goods, services, assets, and capital – between related parties and associated enterprises –must […]
This article examines the inter relationship between Transfer Pricing, Entity’s Tax and Financial Reporting. Due to increasing transfer pricing scrutiny, it is being considered as the most risky area for multinational entities from both compliance and tax planning perspective.
Assessee argued that the clear transactions involving payment of share application money cannot be treated as international transactions of loans given by the assessee company to its AE merely because there was a delay in allotment of shares.
The obligation of an enterprise to keep and maintain records and documents vis-a-vis the duty of revenue authorities to verify about the compliance with the arm’s length principle has been succinctly stated by the OECD in their Transfer Pricing Guidelines:
