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Income Tax : Safe Harbour rules for AY 2022 2023 | Income tax Act, 1961 | Notification No. 66/2022-Income-Tax | Dated: 17th June, 2022 | CBDT...
Delhi High Court Ruling: Transfer Pricing – Sec 92 – An important ruling by the Hon’ble High Court wherein it has been held that the methodology to be adopted by the Revenue Authorities for making an adjustment should be equitable and fair, and has ruled on the payment for the use of intangible assets and attributing arm’s length consideration for activities carried out by the licensee, etc. [Maruti Suzuki India Limited – W.P. 6876/2008]
A General Anti-Avoidance Rule (GAAR) was proposed in the Indian tax legislation for the first time in DTC 2009, apart from Specific Anti-avoidance Rules (SAARs) like transfer pricing (TP) provisions, dividend stripping transactions in securities, dis
With the advent of MNCs(Multi National Concerns) a trend has also been adopted by the MNCs to structure their investments and business strategy in such a way that profits are maximized in such jurisdictions where tax rates are low, which give rise to the emerging problem of transfer pricing all over the world.
ITAT Ruling: Transfer Pricing – Sec 92 – While benchmarking a controlled transaction, mere selling of an identical product to unrelated party is not sufficient for applying Comparable Uncontrolled Price (CUP) as the most appropriate method unless reasonable and accurate adjustments on account of economic and market differences can be arrived to determine the arm’s length price. [M/s Intervet India Private Limited – 2010-TIOL-240- ITAT-MUM].
The US and Indian competent tax authorities have reached a negotiated settlement on transfer pricing dispute in respect of certain captive software development units for the financial year 2004-05. The settlement has been reached through the mutual agreement procedure (MAP) mechanism provided in the Indo-US Double Taxation Avoidance Agreement (DTAA), sources said.
The Finance Act, 2001 substituted section 92 with a new section and introduced new sections 92A to 92F in the Income-tax Act, relating to computation of income from an international transaction in order to facilitate the computation of reasonable, fair and equitable profits and tax in India in the case of businesses carried on by multinational companies. The transfer pricing provisions are in line with those stipulated by OECD. However there is a difference that the Indian legislation does not permit the use of unspecified method to compute arms length price as permitted in OECD guidelines.
The Institute of Chartered Accountants of India (ICAI) plans to familiarise its members, especially the partners of small auditing firms, with the best transfer pricing methods to help them take up larger audit assignments involving companies that have overseas businesses.
The CBDT and OECD are jointly holding an International seminar on transfer pricing at Vigyan Bhawan, New Delhi, India from 17th to 19th February 2010. Shri Pranab Mukherjee, Finance Minister of India, will inaugurate the seminar. Shri. S.S. Palanimanickam Minister of state for Finance (Revenue); Shri. Sunil Mitra, Secretary (Revenue); Shri. S.S.N. Moorthy, Chairman CBDT; Mrs. Caroline Silberztein, Head of transfer pricing unit OECD;
These appeals by the assessee are directed against the separate orders of the CIT(A) for the respective assessment years. Since the issues involved in these appeals are common and connected, and these appeals were heard together, these are being consolidated and disposed of together by this common order.
This is good news for Multi-national companies (MNCs) operating in India. Over 1,600 such companies, who were asked to pay additional corporate taxes on account of their overseas transactions, now, have the option to appeal before the conventional forum of Commissioner (Appeal) as well as Dispute Resolution Panel (DRP) for redressal of their grievances. An appeal before the commissioner (Appeal) may take a year or two for a decision.