#Transfer Pricing
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1,377 articlesIncome Tax
Income Tax
Without reference assumption of jurisdiction by Transfer Pricing Officer in working out arm’s length price not justified
Income Tax
Income Tax
Despite Dependence, Arms’ Length Agent is Not Permanent Establishment (PE)
Income Tax
Income Tax
Transfer Pricing – Non-Reference To TPO Renders Order ‘Erroneous’ and prejudicial to revenue
Income Tax
Income Tax
Transfer Pricing – ALP of Interest-Free Loan – ITAT Delhi Explains Law
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Income Tax
No functions, assets and risks analysis is required before AY 2002-03 for determination of profits attributable to dependent agent permanent establishment; no further attribution if dependent agent paid arm’s length commission
Income Tax
Income Tax
Payment to Foreign healthcare services companies for advising, recommending ,assisting in healthcare projects and for conducting education and training programmes are not royalty
Income Tax
Income Tax
Transfer pricing is founded on the principles of economic substance and hence, it is fact specific – ITAT Pune
Income Tax
Income Tax
Transfer Pricing – Comparable rejected by TPO without giving cogent reasons must be presumed to be comparable and DR cannot argue to the contrary
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Income Tax
Gujrat HC decides at what stage it can be held that there had been an international transaction between taxpayer and its Associated Enterprises
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Income Tax
Understanding Transfer Pricing With Latest Case Laws Part 2
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Income Tax
Software License Income Taxable As ‘Royalty’ – Australian Federal Court
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Income Tax
FM inaugurate International Seminar for Adopting tax System and International tax Rules to the New Global Environment
Income Tax
Income Tax
FM calls for reversal of illicit outflows of funds from Developing Countries to tax havens
Income Tax
Income Tax
