INDIA TRANSFER PRICING UPDATES MARCH 2019
|
|
- Agatha Alexander
- 5 years ago
- Views:
Transcription
1 Uday Ved Global Tax Partner INDIA TRANSFER PRICING UPDATES MARCH 2019 KNAV Thought Leadership has started an initiative to publish a monthly newsletter dedicated to transfer pricing updates and amendments including the recent important jurisprudence. These highlights will help the readers stay abreast of the important developments in the field of transfer pricing. This initiative would be in addition to our monthly newsletters covering the important judgments and other updates from a corporate tax point of view. 1
2 Transfer Pricing Case Law 1: Aamby Valley Ltd. v. ACIT [2019] 102 taxmann.com 385 (TDel) LIBOR rate being a foreign rate should be preferred against SBI s prime lending rate for international transactions with AEs in foreign currency. The assessee-company was engaged in the business of construction. The assessee granted a loan to its associated enterprise ( AE ) for a period of 7 years at an annual interest rate of LIBOR bps ( basis points ). During the transfer pricing proceedings, the Transfer Pricing Officer ( TPO ) rejected the assessee s contention of using LIBOR for benchmarking purposes and stated that LIBOR was not applicable where currency of origin country of loan (India) was not a currency in which loan was extended. TPO contended that assessee erred in assessing the risks associated with international lending transactions. TPO stated that the assessee should have used the standard of the return that it would have earned in India if money was lent here to company with an economic status as weak as the subsidiary. TPO rejected the search conducted by the assessee to for arriving at comparable rate of interest. The TPO relied on the Safe Harbour Rules ( SHR ) where SBI base rate is suggested for benchmarking interest on loan. Aggrieved by the decision, the assessee appealed before the Dispute Resolution Panel ( DRP ) who enhanced the income of the assessee at LIBOR bps. Aggrieved, the assessee filed an appeal before the Hon ble Tribunal. The assessee submitted that SBI is a bank which is engaged in lending of funds to the third parties. The assessee was not a bank / financial institution. Thus, interest on loans advanced by a bank / financial institution and the assessee could not be considered comparable. Further, the assessee stated that when transaction was of lending money in foreign currencies to foreign AEs, interest rates of unrelated third parties lending foreign currencies should be considered comparable. The transaction should be looked upon applying the commercial principles. Thus, domestic prime lending rate would have no applicability and the international fixed rate i.e. LIBOR should be considered, while determining the arm s length interest rate in respect of international transaction entered by the assessee with the AE. As the assessee had calculated the arithmetic mean of interest rate of comparable borrowings advanced by the third parties at LIBOR bps and the assessee had charged LIBOR bps, it was sufficient enough to be considered at an arm s length. 2
3 Case Law 2: CLSA India (P.) Ltd. v. DCIT [2017] 101 taxmann.com 388 (TMum) TPO is bound to determine ALP of an international transaction in accordance with the methods prescribed under the Act. Thus, if any ad hoc determination of ALP is made by TPO the same would not be sustainable and would be bad in law. The assessee-company was primarily engaged in the business of equity broking and had the membership of Bombay Stock Exchange and the National Stock Exchange. The assessee's customers comprised of Foreign Institutional Investors ( FIIs ) and Domestic Institutional Investors ( DIIs ). The assessee entered into agreements with its AEs to provide services in the nature of international equity sales and sales trading support, dealing sport and regional research and a range of back-office support services to its FIIs clients and thereby maintaining international presence and relation. The assessee benchmarked the said international transaction using Transactional Net Marginal Method ( TNMM ) as most appropriate method ( MAM ) wherein the assessee was the tested party. The TPO rejected the assessee s benchmarking of the cost contribution, holding that cost contribution constituted a small part of the total transactions at the entity level and therefore, the profit margin at the entity level could not be the basis for determining the ALP of the cost contribution. The TPO benchmarked the said international transaction by estimating man hours of services rendered by the AE to the assessee and applied an ad hoc hourly rate on estimated hours to determine the arm s length price ( ALP ) i.e. transfer price. Accordingly, the TPO made an upward adjustment to the total income of the assessee. The assessee filed its objections before the DRP against the draft assessment order passed by the AO with an upward adjustment. The DRP, however, confirmed the adjustment and upheld the contention of the AO. Aggrieved by the order, the assessee preferred an appeal with the Hon ble Tribunal. The Hon ble Tribunal relying on the decision rendered by the Hon ble Bombay High Court in case of CIT v. Johnson and Johnson Ltd [2017] 297 CTR 337 (Bom) and held that the ALP determined by the TPO on ad hoc basis was not as per the provisions of the Income Tax Act, 1961 ( the Act ). Further, the tribunal relied on the decision rendered by the Hon ble Bombay High Court in case of CIT vs. Kodak India Pvt Ltd 288 CTR 46 [2017] (Bom) and declined to restore the matter back to the TPO. Accordingly, the Hon ble Tribunal directed the AO to delete the upward adjustment. 3
4 Case Law 3: Sunquest Information Systems India (P.) Ltd. v. DCIT [2019] 101 taxmann.com 315 (TBan) In case of provision of software development services, companies having less than 15% of related party transactions were to be included as comparable. Giving credit is an integral part of rendering business services, and the same could not be an independent transaction, thus having separate determination of ALP. The assessee was engaged in the business of rendering software development services to its AE. The assessee was compensated for the same on cost plus basis. During the transfer pricing proceedings, the TPO rejected the contentions of the assessee, reshuffled the comparables and thereby, recomputed the average mean margin at a higher rate. Accordingly, an addition for the differential amount was made into the assessee s income by the TPO. Further, since the assessee did not receive a part of its receivables from its AEs for a period of more than 3 months, the TPO treated the same as a loan by the assessee to its AE and added notional interest at the SBI lending rate of 11.25% on the contention that the assessee should have used the standard of the return that it would have earned in India if money was lent here to company with an economic status as that of the AE. Aggrieved by the decision, the assessee appealed before the DRP. The DRP excluded a few companies chosen by the TPO applying a turnover filter and RPT filter of 0%. Further, in the case of notional interest the DRP concurred with the finding of the TPO. Aggrieved, the assessee filed an appeal before the Hon ble Tribunal. The Hon ble Tribunal held that based on various case laws mentioned by the assessee and on the facts of the case, companies that possessed less than 15% transactions with the related parties could be included as comparable by the assessee company for computation of ALP for provision of software development services to its AE and accordingly reincluded the said comparables dismissed by the DRP in the computation of the ALP. Further, in the case of addition of notional interest on the receivables from the AE, the Hon ble Tribunal held that giving a credit period could not be considered as an independent transaction and no separate determination of ALP for the same could be derived, as the same was considered as an integral part of the international transaction of software development services and not a separate transaction. 4
5 Case Law 4: M/s. JE Energy Venture Private Ltd. v. ACIT (ITA No.7602/Del/2017) (TDel) As bank guarantees were different from corporate guarantees, naked quotes of BG commission rates published on the websites of the banks could not be applied without relevant adjustments. The assessee-company provided a corporate guarantee on behalf of its AE. The assessee had selected other method prescribed under Income tax rules, 1962 ( the rules ) as the MAM to benchmark the said transaction. The TPO however selected external CUP and applied the data from various banks available on the bank s website for benchmarking purposes and made an upward adjustment to the total income of the assessee. Aggrieved by the decision, the assessee preferred an appeal before the DRP, which gave a partial relief to the assessee. Aggrieved, the assessee preferred appeal before the Hon ble Tribunal. The Hon ble Tribunal stated that the naked quotes of the bank guarantee commission rates published on the website of the bank should not be applied without adjustment to various factors. The adjustments with respect to risk profiles of the respondents for the guarantee, financial position of the applicants, terms of guarantee, securities involved, quantum of the guaranteed amount, period of guarantee, history and relationship with the customers should be considered. Further, bank guarantees were different from corporate guarantees, since a corporate guarantee does not operate for business considerations. Corporate guarantees were provided to safeguard the financial health of the AEs. An external CUP could be defined as a price charged as comparable uncontrolled price between third parties when compared to the price of a controlled transaction with the AE. The comparables used by the TPO did not fall within the definition of external CUP. The Hon ble Tribunal opined that bank guarantee commission prices could not be used as external CUP to benchmark the corporate guarantee commission prices. Therefore, the comparables selected by the TPO were considered as incomparable uncontrolled prices. and the guarantee commission charged by the assessee was considered reasonable and accepted without any modification. 5
6 Case Law 5: B.G. India Energy Solutions (P.) Ltd. v. DCIT [2019] 101 taxmann.com 360 (TDel) The ALP of management services unit charges paid to AE could not to be taken as NIL, if services were not duplicitous in nature and the payment made for these services were recognized separately and not at par with the payment made for the support services required to achieve huge sales volume. The assessee-company was engaged in marketing and distribution of natural gas and LNG. The assessee company paid for certain Management Services Unit Charges ( MSU ) to its AE and used TNMM as the MAM to benchmark the said transaction. The TPO however rejected the assessee s benchmarking and applied CUP as the MAM to benchmark the said transaction and further asked the assessee to justify the reason for the payment for MSU. The assessee explained to the TPO that since it did not have in-house skilled man power, it sought assistance from its AE. The TPO however rejected the plea of the assessee and made an upward TP adjustment and determined ALP of the said transaction at NIL. The assessee filed its objections before the DRP. The DRP however upheld the draft assessment order and thus decided against the assessee. Aggrieved by this, the assessee made an appeal to the Hon ble Tribunal. The Hon ble Tribunal believed the sales of LNG made by the assessee could not have been achieved without the aid of support staff services provided by the AE. Further, on perusal of various clauses mentioned in the agreement entered with the AE, the Hon ble Tribunal held that there was no payment for duplicative services and the payment of MSU charges were distinct and therefore, the adjustment made by the TPO needs to be uncalled for and deserves to be deleted. Case law 6: M/s Infonox Software Pvt. Ltd. v. DCIT [2019] CMA No (Del HC) The ALP of management services unit charges paid to AE could not to be taken as NIL, if services were not duplicitous in nature and the payment made for these services were recognized separately and not at par with the payment made for the support services required to achieve huge sales volume. Summary of the case: The assessee was engaged in the business of providing software development and support services to its clients. Assessee explained that during the relevant year, owing to mismanagement and removal of two directors and non-availability of critical records / financial documents, it was unable to finalize its audited annual accounts and consequently, it was also unable to comply with the statutory requirements of filing its Return of Income and Form 3CEB within due date. 6
7 the TPO. As per the CBDT Instruction, in cases where returns have been selected for scrutiny on transfer pricing risk parameters, reference to the TPO is mandatory. AO initiated reassessment proceedings for the year and directed the assessee to file its return of income along with other statutory documents which were duly complied with by the assessee. Simultaneously, AO also levied penalty u/s 271F of the Act for non-filing of its tax return which was subsequently deleted by the CIT(A), opining that assessee had reasonable and genuine cause for not filing its return of income within the due date. However, for cases which are selected on non-transfer pricing risk parameters, it specifies that they can be referred to the TPO only when a) AO comes to know of an international transaction which has either not been disclosed by the taxpayer in its Form 3CEB or no Form 3CEB has been filed by the taxpayer at all; b) Transfer Pricing Adjustment of INR 10 crores or more has been made, in the hands of the taxpayer, in any of the preceding year(s); c) Incriminating material regarding an international transaction has been recovered during search and seizure operations conducted at the premises of the taxpayer. The AO made a reference to the TPO during the reassessment proceedings of the assessee on the grounds that the assessee did not file Form 3CEB within the specified due date. The assessee defended its case by making a reference of the CBDT instruction 3/2016 which inter-alia permits the reference of the cases selected for scrutiny on non-transfer pricing parameters to TPO, only if Form 3CEB was not filed at all. Assessee also contended that had AO s stand of non-filing of Form 3CEB been correct, the same would have been the very reason for reopening of the assessment. However, the same was not correct as per the facts and circumstances of the case. Assessee has further argued that a return filed in response to a notice received u/s 148 of the Act is equivalent to a return filed u/s 139 of the Act and assessee having filed its return along with report in Form 3CEB as required to be filed u/s 92E of the Act within the time allowed in the said notice, had discharged its obligation and hence, the stand taken by AO that assessee did not file the report u/s. 92E within the due date was incorrect. During the reassessment proceedings, AO issued show cause as to why assessee s case should not be referred to the TPO to determine the ALP for international transactions, as the assessee company failed to file Form 3CEB within specified date. In reply, assessee submitted that its case did not fall within any of the conditions/ circumstances outlined in CBDT Instruction No. 3/2016 so as to warrant a reference to TPO. Assessee also submitted that that it had reasonable cause for not filing its Form 3CEB within the due date and those reasons were accepted by the appellate authority while deleting the penalty levied u/s 271F of the Act. However, AO rejected assessee s submissions on the ground that the Form 3CEB was not filed within the specified date and that prosecution proceedings against the assessee were underway. The Hon ble HC considering the representations by the assessee and the DR has stayed the impugned reference to TPO and issued a notice to the Department. Aggrieved, the assessee filed a writ petition before Hon ble Delhi HC. The assessee, vide its writ petition, challenged the validity of reference made to TPO u/s 92CA(3) of the Act and the order passed by the AO rejecting the objections raised by the assessee against reference to 7
8 Disclaimer: This publication contains general information only, and none of KNAV International Limited, its member firms, or their related entities (collectively, the KNAV Association ) is, by means of this publication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the KNAV Association shall be responsible for any loss whatsoever sustained by any person who relies on this publication. KNAV refers to one or more member firms of KNAV International Limited ('KNAV International'); which itself is a not-for-profit, non-practising, non-trading corporation incorporated in Georgia, USA. KNAV International is a charter umbrella organization that does not provide services to clients. Each firm within KNAV's association of member firms, is a legally separate and independent entity. Services of audit, tax, valuation, risk and business advisory are delivered by KNAV's independent member firms in their respective global jurisdictions. All member firms of KNAV International in India, North America and UK are a part of the US$ 2.01 billion, US headquartered Allinial Global; which is an accounting firm association, that provides a broad array of resources and support for its member firms, across the globe. For expert assistance, please contact Uday Ved: uday.ved@knavcpa.com or Visit us at: 8 Complex, Bandra East, Mumbai, Maharashtra , India Head office: 201/202, Naman Centre, C-31, G Block, Bandra Kurla Other offices: Canada Netherlands Singapore UK USA
Uday Ved Global tax partner INDIA TAX DECEMBER 2018
Uday Ved Global tax partner INDIA TAX DECEMBER 2018 In this edition of our thought leadership publication, we have tracked the progress of some significant cases decided by the appellate forums across
More informationDIRECT TAX UPDATE MARCH, Print SUMMARY OF JUDGEMENTS. Transfer pricing and International taxation issues
Print MARCH, 2015 DIRECT TAX UPDATE SUMMARY OF JUDGEMENTS Transfer pricing and International taxation issues KNAV is a firm of International Accountants, Tax and Business Advisors. Presence in INDIA USA
More informationThe latest guidelines from the ICAI reaffirm specific responsibilities on various stakeholders of Indian companies
Page 1 The latest guidelines from the ICAI reaffirm specific responsibilities on various stakeholders of Indian companies India tax newsletter October, 2016 In this edition of our thought leadership publication,
More informationFacts of the case: Tribunal's decision:
March 2014 1. Transfer Pricing DIRECT TAX UPDATE a. Case law - Panasonic AVC Networks India Co. Limited [ITA No. 4620/Del/2011] KNAV is a firm of International Accountants, Tax and Business Advisors. Presence
More informationINTERNATIONAL TAXATION Case Law Update
CA Tarunkumar Singhal & Sunil Moti Lala, Advocate INTERNATIONAL TAXATION A. SUPREME COURT RULINGS 1. Where the transfer pricing addition made in the final assessment order pursuant to original assessment
More informationTRANSFER PRICING INDIA TAX
Kartik Mehta Senior Manager & Practice Leader, India Direct Tax INDIA TAX July 2018 In this edition of our thought leadership publication, we have tracked the progress of some significant cases decided
More informationThe latest guidelines from the ICAI reaffirm specific responsibilities on various stakeholders of Indian companies
Page 1 The latest guidelines from the ICAI reaffirm specific responsibilities on various stakeholders of Indian companies India tax newsletter September, 2016 In this edition of our thought leadership
More informationDIRECT TAX UPDATE JULY, SUMMARY OF JUDGEMENTS KNAV is a firm of International Accountants, Tax and Business Advisors. Domestic case laws:
JULY, 2015 DIRECT TAX UPDATE SUMMARY OF JUDGEMENTS KNAV is a firm of International Accountants, Tax and Business Advisors. Presence in INDIA USA UK FRANCE NETHERLANDS SWITZERLAND CANADA E: admin@knavcpa.com
More informationINDIA TAX TRANSFER PRICING
Kartik Mehta Senior Manager & Practice Leader, India Direct Tax INDIA TAX May-June, 2018 In this edition of our thought leadership publication, we have tracked the progress of some significant cases decided
More informationITA No.1495/Hyd/10 Four soft Limited, Hyd. ============================
IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD A BENCH, HYDERABAD Before Shri. G.C. Gupta, Vice President and Shri. Akber Basha, Accountant Member ITA No. 1495/HYD/2010 (Assessment year 2006-07) M/s. Four
More informationIndia s High Court of Delhi rules on transfer pricing aspects of intra-group service transactions
30 May 2014 Global Tax Alert News from Transfer Pricing EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/
More informationLandmark Decisions on Transfer Pricing
Landmark Decisions on Transfer Pricing CITC Amol Tibrewal Vispi T. Patel & Associates 11 April 2014 Global Vantedge - Delhi Tribunal (ITA No 2763 & 2764/DEL/2009) Facts of the case Assessee provided IteS
More informationCommissioner of Income Tax Appellant. Versus. M/s. Global Appliances Inc. USA Respondent
11 TH NANI PALKHIVALA MEMORIAL NATIONAL TAX MOOT COURT COMPETITION, 2015 IN THE HIGH COURT OF JUDICATURE AT MADRAS (Ordinary Original Civil Jurisdiction) IN APPEAL NO. OF 2014 IN THE MATTER OF: The Income-tax
More informationINTERNATIONAL TAXATION Case Law Update
Advocate INTERNATIONAL TAXATION Case Law Update A. SUPREME COURT 1) Apex Court admits SLP on whether for computing arm s length price only the value of international transactions and not the assessee s
More informationINTERNATIONAL TAXATION Case Law Update
Advocate INTERNATIONAL TAXATION A. HIGH COURT 1. The Court deleted the disallowance of technical knowhow fees paid in respect of services unavailed by the assessee by relying on its earlier year judgment
More informationITA No.129 & 329/Kol/2016 M/s Bhoruka Investment Ltd. A.Y [Before Hon ble Sri N.V.Vasudevan, JM & Dr.Arjun Lal Saini, AM]
ITA No.129 & 329/Kol/2016 M/s Bhoruka Investment Ltd. A.Y.2012-13 1 IN THE INCOME TAX APPELLATE TRIBUNAL D BENCH : KOLKATA [Before Hon ble Sri N.V.Vasudevan, JM & Dr.Arjun Lal Saini, AM] I.T.A No.129/Kol/2016
More informationAn overview of Transfer Pricing
An overview of Transfer Pricing WIRC of ICAI Vispi T. Patel Vispi T. Patel & Associates 19 th June, 2013 Agenda Transfer Pricing Origin, Evolution and Basic Concepts TP Indian Perspective Indian Transfer
More informationThe Chamber of Tax Consultants 3 rd Intensive Study Course on Transfer Pricing KEY CONTROVERSY AREAS: CASE STUDIES MARCH 30, 2013
The Chamber of Tax Consultants 3 rd Intensive Study Course on Transfer Pricing KEY CONTROVERSY AREAS: CASE STUDIES MARCH 30, 2013 CA MILIND KOTHARI milindkothari@mzsk.in Recent judicial updates Case Study
More informationIN THE INCOME TAX APPELLATE TRIBUNAL B BENCH : BANGALORE
IN THE INCOME TAX APPELLATE TRIBUNAL B BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K., JUDICIAL MEMBER AND SHRI A. MOHAN ALANKAMONY, ACCOUNTANT MEMBER ITA No. 131/Bang/2010 Assessment year : 2004-05 Intel
More informationIN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH `F : NEW DELHI BEFORE SHRI G.E. VEERABHADRAPPA, VICE PRESIDENT AND SHRI C.L.SETHI, JUDICIAL MEMBER.
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH `F : NEW DELHI BEFORE SHRI G.E. VEERABHADRAPPA, VICE PRESIDENT AND SHRI C.L.SETHI, JUDICIAL MEMBER. I.T. A. No.4931/Del/2010 Assessment Year: 2007-08 Quippo
More informationAn overview of Transfer Pricing
An overview of Transfer Pricing WIRC of ICAI Vispi T. Patel 19th June, 2013 Agenda Transfer Pricing Origin, Evolution and Basic Concepts TP Indian Perspective Indian Transfer Pricing Regulations v OECD
More informationGovernment Law College, Mumbai
Government Law College, Mumbai 10 th Nani Palkhivala National Tax Moot Court Competition 2013 3 rd 5 th October, 2013 In association with ITAT Bar Association Mumbai All India Federation of Tax Practitioners
More informationMethods of determining ALP
3 rd Intensive Study Course on Transfer Pricing Methods of determining ALP CA Vishwanath Kane 16 February 2013 Agenda Introduction Transfer Pricing Methods Overview Applicability of Transfer Pricing Methods
More informationTransfer Pricing. Recent Trends & Key Developments. PHD Chamber International Tax Conference September 04, 2014 New Delhi. Statement of Credentials 1
Transfer Pricing Recent Trends & Key Developments PHD Chamber International Tax Conference September 04, 2014 New Delhi Statement of Credentials 1 SESSION DETAILS Topic: Transfer Pricing Recent Trends
More informationMay WHAT'S INSIDE... Direct Tax Transfer Pricing Indirect Tax
May 01-15 WHAT'S INSIDE... Direct Tax Transfer Pricing Indirect Tax What s inside DIRECT TAX 1. Stock Appreciation Rights taxable as perquisites, even if received from parent company 2. Offshore supply
More informationIN INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH G MUMBAI. BEFORE SH. A.D. JAIN, JUDICIAL MEMBER AND SH. RAJENDRA, ACCOUNTANT MEMBER
IN INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH G MUMBAI. BEFORE SH. A.D. JAIN, JUDICIAL MEMBER AND SH. RAJENDRA, ACCOUNTANT MEMBER ITA No.5335/M/2014 Assessment Year: 2007-08 PAN : AABCA8679F Dy. Commr.
More information$~ * IN THE HIGH COURT OF DELHI AT NEW DELHI 9. + W.P.(C) 6422/2013 & CM No.14002/2013 (Stay) versus. With W.P.(C) 4558/2014.
$~ * IN THE HIGH COURT OF DELHI AT NEW DELHI 9. + W.P.(C) 6422/2013 & CM No.14002/2013 (Stay) INDORAMA SYNTHETICS (INDIA) LTD.... Petitioner Through: Mr. Ajay Vohra, Senior Advocate with Ms. Kavita Jha
More informationIN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : I : NEW DELHI
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES : I : NEW DELHI BEFORE SHRI R.S. SYAL, AM AND SHRI GEORGE GEORGE K. JM ITA No.282/Del/2012 Assessment Year : 2003-04 DCIT, Circle 11(1), Room No.312,
More informationIN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION. WRIT PETITION No OF 2004
IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION WRIT PETITION No. 3314 OF 2004 wp-3314-2004.sxw M/s. Eskay K'n' IT (India) Ltd... Petitioner. V/s. Dy. Commissioner of Income
More informationIndia. Vispi T. Patel and Kejal P. Visharia*
India Vispi T. Patel and Kejal P. Visharia* Ruling in Marubeni Case on Benchmarking and Determining Arm s Length Consideration for the International Provision of Agency and Marketing Support Services The
More informationBroad Overview of Transfer Pricing Provisions in India and Current Key Issues faced by Tax-payer
CA. Vispi T. Patel, CA. Rajiv Shah and CA.Kejal Visharia Broad Overview of Transfer Pricing Provisions in India and Current Key Issues faced by Tax-payer INTERNATIONAL PRICING PROVISIONS TRANSFER Introduction
More informationOverview of Transfer Pricing
Overview of Transfer Pricing Contents Legislative framework Transfer pricing study Assessment and Litigation Key Recent Developments Page 2 Transfer Pricing in India- Background April 1, 2001 onwards Comprehensive
More informationIntroduction to Transfer Pricing Regulations
Introduction to Transfer Pricing Regulations January 24, 2015 Vispi T. Patel Vispi T. Patel & Associates 1 Agenda Transfer Pricing Regulations in India Practical applicability of Transfer Pricing Regulations
More informationIN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: G NEW DELHI BEFORE SHRI G. D. AGRAWAL, PRESIDENT AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER
1 ITA Nos. 6675 & 6676/Del/2015 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: G NEW DELHI BEFORE SHRI G. D. AGRAWAL, PRESIDENT AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER ITA No. 6675/DEL/2015 ( A.Y 2013-14)
More information2 the order passed by the AO dated for AY , on the following grounds:- 1 : Re.: Treating the reimbursement of the expenses as income
IN THE INCOME TAX APPELLATE TRIBUNAL "L" Bench, Mumbai Shri C.N. Prasad (Judicial Member) & Before Shri Ashwani Taneja (Accountant Member) ITA No.4659/Mum/2014-2009-10 ITA No.385/Mum/2016-2011-12 Dy.CIT
More informationIN THE INCOME TAX APPELLATE TRIBUNAL A BENCH : BANGALORE. BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER and SHRI JASON P BOAZ, ACCOUNTANT MEMBER
IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH : BANGALORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER and SHRI JASON P BOAZ, ACCOUNTANT MEMBER ITA No.726/Bang/2014 (Assessment year: 2005-06) M/s.B & B Infotech
More informationMumbai Tribunal rules on transfer pricing aspects of intra-group software development services
13 March 2013 Global Tax Alert News and views from Transfer Pricing Mumbai Tribunal rules on transfer pricing aspects of intra-group software development services Executive summary This Tax Alert summarizes
More informationIN THE INCOME TAX APPELLATE TRIBUNAL : NEW DELHI VICE PRESIDENT, SHRI S.V.MEHROTRA, ACCOUNTANT MEMBER AND SHRI RAJPAL YADAV, JUDICIAL MEMBER
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI SPECIAL BENCH C : NEW DELHI BEFORE SHRI G.D.AGRAWAL, VICE PRESIDENT, SHRI S.V.MEHROTRA, ACCOUNTANT MEMBER AND SHRI RAJPAL YADAV, JUDICIAL MEMBER ITA No.5890/Del/2010
More informationTransfer Pricing adjustment in relation to intra-group services deleted; payment of 2 per cent on sales considered to be at arm s length
16 February 2016 Transfer Pricing adjustment in relation to intra-group services deleted; payment of 2 per cent on sales considered to be at arm s length Background Recently, the Kolkata Bench of the Income
More information$~ * IN THE HIGH COURT OF DELHI AT NEW DELHI ITA 607/2015. versus AND ITA 608/2015. versus
$~ * IN THE HIGH COURT OF DELHI AT NEW DELHI 12. + ITA 607/2015 PR. COMMISSIONER OFINCOME TAX... Appellant Through: Mr. Kamal Sawhney, Senior Standing counsel with Mr. Raghvendra Singh and Mr.Shikhar Garg,
More informationIN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B, HYDERABAD BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER AND SHRI SAKTIJIT DEY, JUDICIAL MEMBER
IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B, HYDERABAD BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER AND SHRI SAKTIJIT DEY, JUDICIAL MEMBER ITA No. 1743/Hyd/2013 Assessment Year : 2009-10 Bellwether
More informationCA SHARAD A SHAH. 21/06/2014 DTRC - Pune WIRC
CA SHARAD A SHAH 21/06/2014 DTRC - Pune WIRC-2014 1 Relevant Part of Section 271 (1) If the Assessing Officer] or the [Commissioner (Appeals)][or the Commissioner] in the course of any proceedings under
More informationINTERNATIONAL TAXATION Case Law Update
Advocate INTERNATIONAL TAXATION Case Law Update A] HIGH COURT JUDGMENTS I. ALP of interest on amounts advanced to German AE was to be determined based on EURIBOR rate of interest and not the lending rate
More information(Applicability & impact Analysis) By:-
Domestic Transfer Pricing (Applicability & impact Analysis) By:- Surana Maloo & Co. Chartered Accountants 2 nd Floor, Aakash Ganga Complex, Parimal Under Bridge, Nr Suvidha Shopping Center, Paldi, Ahmedabad-
More informationIN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH K, MUMBAI BEFORE SHRI G.S.PANNU, ACCOUNTANT MEMBER AND SHRI SANDEEP GOSAIN, JUDICIAL MEMBER
IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH K, MUMBAI BEFORE SHRI G.S.PANNU, ACCOUNTANT MEMBER AND SHRI SANDEEP GOSAIN, JUDICIAL MEMBER ITA No. 859/MUM/2014 Thomas Cook (India) Limited, Thomas Cook
More informationTax Dispute Resolution in India - How to effectively handle? Sanjay Sanghvi 29 April 2017
Tax Dispute Resolution in India - How to effectively handle? Sanjay Sanghvi 29 April 2017 Income Tax in India An overview Residents taxed on worldwide income Non-residents taxed on Indian sourced income
More informationPractical aspects - Documentation, Benchmarking and Transfer Pricing Analysis IT/ITES, KPO and Engineering. Vaishali Mane Mumbai
Practical aspects - Documentation, Benchmarking and Transfer Pricing Analysis IT/ITES, KPO and Engineering Vaishali Mane Mumbai Agenda Transfer Pricing A quick background Operation Challenges Litigation
More informationCBDT Instruction No. 3/2016 : A game-changer for TP audits? - Part I
CBDT Instruction No. 3/2016 : A game-changer for TP audits? - Part I Date: Fri, 04/22/2016-15:02 Ajay Kering (Direct or, Grant Thornt on India LLP) Dinesh Ramnani (Manager, Grant Thornt on India LLP) This
More informationSharing insights. News Alert 28 February TPO not justified in recalculating royalty based on his own interpretation of term, Net Sales.
www.pwc.in Sharing insights News Alert 8 TPO not justified in recalculating royalty based on his own interpretation of term, Net Sales In brief In a recent ruling 1, the Pune Income-tax Appellate Tribunal
More informationIN THE INCOME TAX APPELLATE TRIBUNAL PANAJI BENCH, PANAJI
IN THE INCOME TAX APPELLATE TRIBUNAL PANAJI BENCH, PANAJI BEFORE SHRI N.S. SAINI, HON BLE ACCOUNTANT MEMBER AND SHRI GEORGE MATHAN, HON BLE JUDICIAL MEMBER (Asst. Year : 2009-10) DCIT, Circle-1(1), Panaji.
More informationThe latest guidelines from the ICAI reaffirm specific responsibilities on various stakeholders of Indian companies
Page 1 The latest guidelines from the ICAI reaffirm specific responsibilities on various stakeholders of Indian companies India tax newsletter May, 2017 In this edition of our thought leadership publication,
More informationIN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH B BENCH BEFORE SHRI B.R.MITTAL(JUDICIAL MEMBER) AND SHRI RAJENDRA (ACCOUNTANT MEMBER)
IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH B BENCH BEFORE SHRI B.R.MITTAL(JUDICIAL MEMBER) AND SHRI RAJENDRA (ACCOUNTANT MEMBER) Assessment Year: 1999-2000 Bennett Coleman & Co.Ltd., The Times
More informationFundamental principles of Transfer Pricing and Transfer Pricing audit under the Income-tax Act, 1961
Fundamental principles of Transfer Pricing and Transfer Pricing audit under the Income-tax Act, 1961 Borivali (Central) CPE Study Circle of WIRC of The Institute Of Chartered Accountants Of India Vispi
More informationVs. Vs. Mr. Anuj Kisnadwala, Adv. Date of Hearing 22/06/2016 Date of pronouncement 02/06/2016 O R D E R
INCOME TAX APPELLATE TRIBUNAL DELHI BENCH C : NEW DELHI BEFORE SHRI S.V. MEHROTRA, ACCOUNTANT MEMBER AND SMT. BEENA A PILLAI, JUDICIAL MEMBER ITA No.:- 283/Del/2012 Assessment Year: 2005-06 DCIT Circle-11(1),
More informationLoreal India P. Ltd, Mumbai vs Department Of Income Tax on 12 April, 2012
Income Tax Appellate Tribunal - Mumbai Loreal India P. Ltd, Mumbai vs Department Of Income Tax on 12 April, 2012 IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH 'L' BENCH BEFORE SHRI B.R.MITTAL(JUDICIAL
More informationCORAM: HON'BLE DR. JUSTICE S.MURALIDHAR HON'BLE MR. JUSTICE VIBHU BAKHRU O R D E R %
$~ * IN THE HIGH COURT OF DELHI AT NEW DELHI 10. + ITA 102/2015 RAMPGREEN SOLUTIONS PVT LTD... Appellant Through: Mr Ajay Vohra, Sr. Advocate with Mr Aditya Vohra, Advocate. versus COMMISSIONER OF INCOME
More informationMethodology to benchmark Intra group services, Management services and Cost allocation
Methodology to benchmark Intra group services, Management services and Cost allocation with case study Presentation for 3rd Intensive Study Course on Transfer Pricing Organised by The Chamber Of Tax Consultants
More informationTransfer Pricing Issues - IT/ITES Industry - Financial Services Industry. Darpan Mehta March 20, 2015
Transfer Pricing Issues - IT/ITES Industry - Financial Services Industry Darpan Mehta March 20, 2015 Agenda IT/ITES Industry 1 Financial Services Industry 2 Slide 2 IT/ITES Industry 1 Issues and challenges
More informationPractical Issues in Transfer Pricing Assessment
THE INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA Practical Issues in Transfer Pricing Assessment CA DIGESH RAMBHIA Synopsis Current Indian Transfer Pricing ( TP ) Environment Experiences in TP Audits Key
More informationTRANSFER PRICING 360 o
TRANSFER PRICING 360 o Volume 5 Issue 3 November 2018 Transfer pricing litigation environment in India has been evolving over a period of time. In recent past, Indian courts have provided judgment on complex
More informationIN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH. M/s Lakhani Marketing Incl., Plot No.131, Sector 24, Faridabad
1 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH Commissioner of Income Tax, Faridabad Vs. ITA No.970 of 2008 (O&M) Date of decision:02.04.2014 Appellant M/s Lakhani Marketing Incl., Plot No.131,
More informationSUMMARY OF JUDGEMENTS
JUNE, 2015 DIRECT TAX UPDATE SUMMARY OF JUDGEMENTS KNAV is a firm of International Accountants, Tax and Business Advisors. Presence in INDIA USA UK FRANCE NETHERLANDS SWITZERLAND CANADA E: admin@knavcpa.com
More informationIN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES, D, MUMBAI BEFORE SHRI R.S.SYAL, ACCOUNTANT MEMBER AND SHRI VIJAY PAL RAO, JUDICIAL MEMBER
IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES, D, MUMBAI BEFORE SHRI R.S.SYAL, ACCOUNTANT MEMBER AND SHRI VIJAY PAL RAO, JUDICIAL MEMBER ITA No. 2210/Mum/2010 (Assessment Years: 2006-07) Renu Hingorani
More informationSharing insights. News Alert 1 February, 2012
www.pwc.com/in Sharing insights News Alert 1 February, 2012 Sharing of net revenues consistently in controlled and uncontrolled transactions held as a valid comparable uncontrolled price In brief In a
More informationCONTENTS. Introduction to Transfer Pricing. Transfer Pricing Litigation Statistics. Introduction to Domestic Transfer Pricing
DOMESTIC TRANSFER PRICING CONTENTS Introduction to Transfer Pricing Transfer Pricing Litigation Statistics Introduction to Domestic Transfer Pricing Section 40A(2)(b), 80IA(8) & 80IA(10) Relationships,
More informationAn overview of Transfer Pricing
An overview of Transfer Pricing CTC Vispi T. Patel Vispi T. Patel & Associates Agenda Transfer Pricing Origin, Evolution and Basic Concepts TP Indian Perspective Indian Transfer Pricing Regulations v OECD
More informationIN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH G NEW DELHI SHRI I.C. SUDHIR, JUDICIAL MEMBER & SHRI L.P. SAHU, ACCOUNTANT MEMBER
IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH G NEW DELHI BEFORE : SHRI I.C. SUDHIR, JUDICIAL MEMBER & SHRI L.P. SAHU, ACCOUNTANT MEMBER ITA No. 2976/Del./2013 Asstt. Year : 2009-10 Silicon Graphics
More informationTHE HIGH COURT OF DELHI AT NEW DELHI. % Judgment delivered on: THE COMMISSIONER OF INCOME TAX. - versus M/S ZORAVAR VANASPATI LIMITED
THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 24.07.2009 + ITA 596/2005 THE COMMISSIONER OF INCOME TAX Appellant - versus M/S ZORAVAR VANASPATI LIMITED... Respondent Advocates who appeared
More informationTax and Transfer Pricing Alert Insight with information
India Tax & Regulatory For private circulation only 31 May 2017 p Tax and Transfer Pricing Alert Insight with information Every outstanding receivables does not constitute an international transaction.
More informationIN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: H : NEW DELHI BEFORE SHRI I.C. SUDHIR, JUDICIAL MEMBER AND SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: H : NEW DELHI BEFORE SHRI I.C. SUDHIR, JUDICIAL MEMBER AND SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER ITA No. 1322 /Del/2012 Assessment Year: 2003-04 Asstt.
More informationTransfer Pricing Methods and Selection of Most Appropriate Method. Vaishali Mane Partner Grant Thornton India LLP Mumbai
Transfer Pricing Methods and Selection of Most Appropriate Method Vaishali Mane Partner Grant Thornton India LLP Mumbai Agenda Transfer Pricing Quick background Arm's Length Principle Overview of Methods
More informationTRANSFER PRICING DEVELOPMENTS IN INDIA
TRANSFER PRICING DEVELOPMENTS IN INDIA T. P. Ostwal & Associates LLP Nanubhai Desai & Co. D T S & Associates For private circulation & internal use only This publication does not constitute professional
More informationTHE HIGH COURT OF DELHI AT NEW DELHI
THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 28.11.2011 + ITA 938/2011 COMMISSIONER OF INCOME TAX... Appellant versus AMADEUS INDIA PVT LTD... Respondent Advocates who appeared in this
More informationIN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: E : NEW DELHI BEFORE SMT. DIVA SINGH, JUDICIAL MEMBER AND SH. O.P. KANT, ACCOUNTANT MEMBER
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: E : NEW DELHI BEFORE SMT. DIVA SINGH, JUDICIAL MEMBER AND SH. O.P. KANT, ACCOUNTANT MEMBER Assessment Year: 2006-07 M/s. Ujagar Holdings Pvt. Ltd., 8-D,
More informationIN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH A, HYDERABAD
IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH A, HYDERABAD BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER ITA No. 842/HYD/2012 Assessment Year: 2007-08,
More informationSeptember WHAT'S INSIDE... Direct Tax Transfer Pricing Indirect Tax
September 16-30 WHAT'S INSIDE... Direct Tax Transfer Pricing Indirect Tax What s inside DIRECT TAX 1. Payment for technical services made for earning future source of income outside India is covered by
More informationFuture of TP. Documentation & Certification. 7th October Presented by- CA Dilip Gupta
Future of TP Documentation & Certification 7th October 2017 Presented by- CA Dilip Gupta Journey of TP regulations in India Major Milestones Final Rules on Range and multiple year data concept Introduction
More informationINTERNATIONAL TAXATION Case Law Update
CA Tarunkumar Singhal & Sunil Moti Lala, Advocate A. HIGH COURT 1. The Court confirmed Tribunal s Order holding that the commission payments made to Indian agent of non-resident in India was taxable in
More informationRecent Judicial Decisions & Developments in Transfer Pricing in India
Recent Judicial Decisions & Developments in Transfer Pricing in India Presented at International Tax Conference, Mumbai 5 th Dec 2009 By Ms Alpana Saksena Indian Revenue Service Commissioner Income Tax
More informationआयकर अप ऱ य अध करण प ण न य यप ठ ए प ण म
आयकर अप ऱ य अध करण प ण न य यप ठ ए प ण म IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH A, PUNE स श र स षम च वऱ, न य ययक सदस य एव श र अय ऱ चत व द, ऱ ख सदस य क समक ष BEFORE MS. SUSHMA CHOWLA, JM AND SHRI
More informationIN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH.
IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH. (O&M) Date of decision: 4.8.2010 M/s V.K. Timber Pvt. Ltd. -----Appellant. Vs. Commissioner Income Tax (Appeals) & another. -----Respondents CORAM:-
More informationIN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE A BENCH, BANGALORE
IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE A BENCH, BANGALORE BEFORE SMT P.MADHAVI DEVI, JUDICIAL MEMBER AND SHRI ABRAHAM P GEORGE, ACCOUNTANT MEMBER ITA Nos.220 & 1043(BNG.)/2013 (Assessment year
More informationKey Transfer Pricing Rulings
Key Transfer Pricing Rulings 8 Sept 2017 - Prasad Pardiwala Presenters : Rahul & Pranav Case Law - 1 Instrumenterium Special bench on Base Erosion Facts/ Issue: The taxpayer advanced an interest free loan
More informationIssues in Transfer Pricing
Issues in Transfer Pricing Vaishali Mane Chartered Accountant, Mumbai 2017 Grant Thornton India LLP. All rights reserved. 1 Contents 1 Transfer Pricing - Basic 2 Recent Developments in Transfer Pricing
More informationIN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B, HYDERABAD
IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH B, HYDERABAD BEFORE SHRI P.MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA No. 503/Hyd/2012 Assessment Year: 2008-09,
More informationBefore Sh. J. S. Reddy, AM And Sh. George George K., JM
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH A, NEW DELHI Before Sh. J. S. Reddy, AM And Sh. George George K., JM : Asstt. Year : 2007-08 Dy. Commissioner of Income Tax, Central Circle-7 New Delhi
More informationDIRECT TAXES Tribunal
Jitendra singh & sameer dalal Advocates DIRECT TAXES Tribunal REPORTED 1. TDS under section 194I provision for rent vis-à-vis actual payment assessee making provisions for disputed rent payable to landlord
More information2. Kawasaki Heavy Industries Ltd Vs ACIT ITA No. 1321/Del/2015 dt
Recent Judgments : February March 2016 By Ms. Bhavya Rangarajan, Advocate Ms. B. Mala, Associate Subbaraya Aiyar, Padmanabhan & Ramamani (SAPR) Advocates 1. Shri B.L.Shah Vs ACIT ITA No. 910 of 2007 dt
More informationTRANSFER PRICING ( TP ) LITIGATION TP ASSESSMENT AND DISPUTE RESOLUTION PANEL ( DRP )
TRANSFER PRICING ( TP ) LITIGATION TP ASSESSMENT AND DISPUTE RESOLUTION PANEL ( DRP ) Contributed by : CA Kushal Dedhia (a member of the association) he can be reached at kushaldedhia05@gmail.com Your
More informationBackground. Facts of the case. 11 April 2016
11 April 2016 Turnover filter considered at 10 times; Comparables with RPTs up to 15 percent accepted; standard deduction of +/- 5 percent benefit under the erstwhile provisions of Incometax Act confirmed
More informationTransfer Pricing and Other Provisions to Check Avoidance of Tax
16 Transfer Pricing and Other Provisions to Check Avoidance of Tax Question 1 State the consequences that would follow if the Assessing Officer makes adjustment to arm s length price in international transactions
More informationIN THE HIGH COURT OF DELHI AT NEW DELHI SUBJECT : INCOME TAX MATTER. ITA No.798 /2007. Judgment reserved on: 27th March, 2008
IN THE HIGH COURT OF DELHI AT NEW DELHI SUBJECT : INCOME TAX MATTER ITA No.798 /2007 Judgment reserved on: 27th March, 2008 Judgment delivered on:7th April, 2008 Commissioner of Income Tax Delhi-II, New
More informationIN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI D BENCH MUMBAI BENCHES, MUMBAI BEFORE SHRI VIJAY PAL RAO, JM & SHRI RAJENDRA, AM
IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI D BENCH MUMBAI BENCHES, MUMBAI BEFORE SHRI VIJAY PAL RAO, JM & SHRI RAJENDRA, AM Reliance Industrial Infrastructure Ltd 5 th Floor, NKM International House 178
More informationIN THE HIGH COURT OF KARNATAKA AT BANGALORE PRESENT THE HON'BLE MR.JUSTICE DILIP B.BHOSALE AND THE HON'BLE MR.JUSTICE B.MANOHAR ITA NO.
1 IN THE HIGH COURT OF KARNATAKA AT BANGALORE DATED THIS THE 05 TH DAY OF MARCH 2014 PRESENT THE HON'BLE MR.JUSTICE DILIP B.BHOSALE AND THE HON'BLE MR.JUSTICE B.MANOHAR BETWEEN: ITA NO.828/2007 H.Raghavendra
More information2 nd All India Tax Summit. - Achromic Point. Transfer Pricing. CA Sachin Kumar B P
2 nd All India Tax Summit - Achromic Point Transfer Pricing CA Sachin Kumar B P 2001: TP regulations introduced -Mandatory compliance agreement - Stringent penalty provisions 2005: First TP audit cycle
More informationCommissioner of Income Tax 24
vikrant 1/16 6 ITXA 1709 2014+.odt IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO. 1709 OF 2014 Commissioner of Income Tax 20 Shri. Deepak Kumar Agarwal
More informationIN THE INCOME TAX APPELLATE TRIBUNAL H BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER ब म/
आयकर अप ल य अध करण H न य यप ठ म बई म IN THE INCOME TAX APPELLATE TRIBUNAL H BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER आयकर अप ल स./ (न रण वर / Assessment
More informationBOOK ONE GENERAL PRINCIPLES OF TRANSFER PRICING
CONTENTS BOOK ONE GENERAL PRINCIPLES OF TRANSFER PRICING CHAPTER 1 : INTRODUCTION 3 CHAPTER 2 : FEATURES OF THE TRANSFER PRICING REGIME UNDER CHAPTER X 10 CHAPTER 3 : TRANSFER PRICING PROVISIONS OF CHAPTER
More informationIN THE HIGH COURT OF DELHI AT NEW DELHI SUBJECT : INCOME TAX ACT. Reserved on: 19th March, Date of Decision: 25th April, 2014
IN THE HIGH COURT OF DELHI AT NEW DELHI W.P.(C) 3891/2013 SUBJECT : INCOME TAX ACT Reserved on: 19th March, 2014 Date of Decision: 25th April, 2014 SAMSUNG INDIA ELECTRONICS PVT. LTD... Petitioner Through
More informationIN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH F, NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH F, NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER INCOME TAX OFFICER, WARSD 15(3), NEW DELHI ROOM NO.
More information