Income Tax : Explore the concept of transaction recharacterization in transfer pricing. Understand its rationale, benefits, and challenges in g...
Income Tax : Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023....
Income Tax : India's Transfer Pricing regulations for FY 2023-24 (AY 2024-25) - This detailed chart lists key activities, legal sections, requi...
CA, CS, CMA : Learn about transfer pricing, its importance, methods, documentation, penalties for non-compliance, and advanced pricing agreement...
Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : Voice Of CA has made a Request for Extension of specified date of filing Tax Audit Report and other forms falling due on or before...
Income Tax : ITAT Hyderabad directed to exclude companies having turnover of more than or less than 10 times of the turnover of the assessee fr...
Income Tax : ITAT Mumbai held that no transfer pricing adjustment could have been made in the hands of assessee on account of ALP of specified ...
Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...
Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...
Income Tax : ITAT Delhi rules RPM as the best method for benchmarking solar goods purchases in the D Light Energy P. Ltd. vs Assessing Officer ...
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...
Income Tax : Safe Harbour rules for AY 2022 2023 | Income tax Act, 1961 | Notification No. 66/2022-Income-Tax | Dated: 17th June, 2022 | CBDT...
Tarun Gulati Earlier, India was isolated from the world markets and it went global only in 1991 with the change in policies for Foreign Trade, foreign direct investments, etc. This move towards globalization brought in new requirement for changes in the taxation and other laws as the MNC’s started investing in India and acquisition of […]
Change is what has bought us to the juncture and change is what it will take to usher in a new future as we contemplate way to address the challenges. Many changes have focused on bringing in greater clarity while others have expanded the scope of its operations. Indian Transfer Pricing ambit has been changed with introduction of Safe Harbour Rules (SHR), Advance Pricing Agreements (APA) & Dispute Resolution Panel (DRP).
Pursuant to the Safe Harbour Rules in Rules 10TA to 10TG, the CBDT has issued a letter dated 20.12.2013 in which it has laid down important directives and clarifications on the manner in which the Safe Harbour Rules are meant to be implemented. The directives and clarifications are as follows:
Under section 92E, every person who enters into an international transaction during a previous year is required to obtain a report from a chartered accountant and furnish such report on or before the specified date on the prescribed form. Rule 10E provides that the auditor’s report shall be in Form No.3CEB.
Recently Learned CA T.P. Ostwal has commented on Transfer Pricing issues while addressing a WEBCAT for ICAI on Overview of Transfer Pricing that ” TP is not art, its not science….. its magic!” He further point out the following deficiencies :-
ICAI has requested CBDT to extend the due date of e‐filing of income‐tax returns, tax audit reports and report under section 92E of the Income‐tax Act, 1961
Safe Harbour Rules Finalized after Considering Comments of Various Stake Holders ; Rules to be Applicable for 5 Assessment Years Beginning from Assessment Year 2013-14 Section 92CB of the Income-tax Act provides for framing of safe harbour rules. The determination of arms length price u/s 92C or 92CA of the Act is subject to these […]
The petitioner, a company incorporated under the Companies Act, 1956, seeks a writ of certiorari to quash and set aside a Transfer Pricing Order dated 31 st October, 2011, passed by respondent No.2 – Additional Commissioner of Income-tax, Transfer Pricing
Tax Evasion by Foreign Companies Data on dollars transferred abroad by foreign companies in India is not centrally maintained by the government. However, with a view to prevent shifting of profits out of India and consequent erosion of the Indian tax base, selected international transactions undertaken are analysed every year in accordance with the transfer […]
In order to reduce the increasing number of transfer pricing audits and prolonged disputes, the Finance (No.2) Act, 2009 w.r.e.f 1.4.2009 inserted a new section 92CB to provide that determination of arm’s length price under section 92C or Section 92CA shall be subject to safe harbour rules. Vide this amendment, the Government of India had empowered the CBDT to make Safe Harbour rules. Safe harbour was defined to mean circumstances in which the income-tax authorities shall accept the transfer price declared by the assessee.
