Tag Archives: transfer pricing

Transfer pricing not applicable between Indian Head Office and Foreign Branch

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 »

Book on Transfer Pricing [2016 Edition]

Guide To Transfer Pricing With Transfer Pricing Audit (ENGLISH) BUY Specifications of Guide To Transfer Pricing With Transfer Pricing Audit (ENGLISH) (Paperback) BOOK DETAILS Publisher TAXMANN ISBN-10 9350719126 Edition 2016 Publication Year 2016 MAY Language ENGLISH ISBN-13 9789350719121 Binding Paperback

Arm’s length price for Assessment Year 2016-2017

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 »

segmental data : Cross-examining comparable companies’ personnel

The Transfer Pricing Officer used “segmental data” from several companies—data that did not form part of these companies’ audited accounts—in determining the arms’ length price. The taxpayer was not provided an opportunity to cross-examine the comparable companies’ authorised personnel who had provided the segmental data. The High Court found that in light of the tax… Read More »

Digest of 700 judgements on Transfer Pricing, International Tax and Domestic Tax

Judgements on Transfer Pricing, International Tax and Domestic Tax Transfer Pricing – Page 2 International Tax – Page 42 Domestic Tax – Page 57 International transactions Cases 1 to 11 Permanent Establishment Cases 243 to 256 Income – Cases 321 to 330 Most Appropriate Method Royalty / Fees for technical services – Cases 257 to… Read More »

Guidance to TPOs and AOs to operationalise transfer pricing provisions

sections 92 to 92F in Chapter X of the Income-tax Act, 1961 INSTRUCTION NO.3/2016 [F.NO.500/9/2015-APA-II], DATED 10-3-2016 The provisions relating to transfer pricing are contained in sections 92 to 92F in Chapter X of the Income-tax Act, 1961. These provisions came into force w.e.f. Assessment Year 2002-2003 and have seen a number of amendments over… Read More »