Tag Archives: Section 92C

Transfer Pricing Tolerance Limit for AY 2017-18 & 2018-19 Notified

By | June 10, 2017

MINISTRY OF FINANCE (Department of Revenue) NOTIFICATION New Delhi, the 9th June, 2017 [Income-tax] S.O. 1866(E).—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)(hereinafter referred to as the ‘Act’), read with proviso to sub-rule (7) of rule 10CA of the… Read More »

Transfer pricing not applicable between Indian Head Office and Foreign Branch

By | November 3, 2016

Held The transfer pricing provisions cannot apply in respect of transactions between the Indian head office and branch office in Canada. (para 8) IN THE ITAT DELHI BENCH ‘I-1’ Aithent Technologies (P.) Ltd. v. Deputy Commissioner of Income Tax, Circle-1(1) R.S. SYAL, ACCOUNTANT MEMBER AND KULDIP SINGH, JUDICIAL MEMBER IT APPEAL NO. 6446 (DELHI) OF… Read More »

Arm’s length price for Assessment Year 2016-2017

By | July 19, 2016

THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)] MINISTRY OF FINANCE (Department of Revenue) NOTIFICATION New Delhi, the 14th July, 2016 [INCOME TAX] S. O. 2425(E).—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), read with proviso to sub-rule (7)… Read More »

Manufacturer of tractor not comparable with harvester combine

By | October 23, 2015

A manufacturer of tractor cannot be considered as comparable with manufacturer of harvester combine, simply because both machines fall in overall category of ‘Agricultural equipments’ IN THE ITAT DELHI BENCH ‘I’ Deputy Commissioner of Income-tax, Circle- 3 (1), New Delhi v. Claas India (P.) Ltd. R.S. SYAL, ACCOUNTANT MEMBER AND A.T. VARKEY, JUDICIAL MEMBER IT… Read More »

Transfer Pricing Non-voice based BPO can be compared with voice based BPO

By | August 3, 2015

Question Whether  Non-voice based BPO can be compared with voice based BPO for purpose of TP study ? Answer:  Non-voice based BPO can’t be compared with voice based BPO for purpose of TP study IN THE ITAT KOLKATA BENCH ‘C’ Acclaris Business Solutions (P.) Ltd. v. Income-tax Officer, Ward No. 2(2), Kolkata MAHAVIR SINGH, JUDICIAL… Read More »