Tag Archives: transfer pricing

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 Budget 2017 Amendments -Webinar

By | February 21, 2017

BMR Advisors Webinar on the Finer nuances of Transfer Pricing Budget 2017 Amendments Published on Feb 15, 2017 One of the key amendment proposed by the Finance Bill, 2017 is introducing the concept of secondary adjustment by the insertion of Section 92CE to the Act. This has been widely debated in India and also used… 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 »

Guide to Transfer Pricing with Transfer Pricing Audit -Book 2016

By | September 27, 2016

Guide to Transfer Pricing with Transfer Pricing Audit Paperback – 2016 BUY Guide to Transfer Pricing with Transfer Pricing Audit Paperback – 2016 As amended by Finance Act 2016 Paperback: 1308 pages Publisher: Taxmann; 6th Edition edition (2016) Language: English ISBN-10: 9350719126 ISBN-13: 978-9350719121 Product Dimensions: 23.9 x 15 x 4.6 cm  

web hosting co. isn’t comparable with co. rendering software development services

By | September 21, 2016

Radisys India (P.) Ltd. v. Income-tax Officer, Ward- 5 (1), Bangalore , JUDICIAL MEMBER AND ABRAHAM P. GEORGE, ACCOUNTANT MEMBER ABRAHAM P. GEORGE IT (TP) APPEAL NOS. 345 & 371 (BANG.) OF 2015 [ASSESSMENT YEAR 2010-11] SEPTEMBER  4, 2015 Smt. Mahaveer C. Jain, CA for the Appellant. Sunil Kumar Agarwal, CIT-DR-I for the Respondent. ORDER… Read More »

Book on Transfer Pricing With Transfer Pricing Audit -2016 Edition

By | September 16, 2016

Guide To Transfer Pricing With Transfer Pricing Audit (ENGLISH)  (Paperback, TAXMANN) This Book on Transfer Pricing contains detailed provisions on Transfer pricing as amended by Finance Act 2016 (India) You can Click to BUY this book online Features of Book on Transfer Pricing With Transfer Pricing Audit Language: ENGLISH Binding: Paperback Publisher: TAXMANN Genre: Professional ISBN: 9789350719121, 9350719126 Publication Year… Read More »

Use of Berry ratio as a PLI in limited circumstances

By | July 24, 2016

HIGH COURT OF DELHI Sumitomo Corporation India (P.) Ltd. v. Commissioner of Income-tax S. MURALIDHAR AND VIBHU BAKHRU, JJ. IT APPEAL NOS. 381,382 OF 2013 & 702 OF 2014 AND 738 OF 2015 JULY  22, 2016 C.S. Aggarwal, Senior Advocate, Prakash Kumar and Himanshu Sinha, Advocates for the Appellant. Ashok K. Manchanda Senior Standing Counsel… 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 »

segmental data : Cross-examining comparable companies’ personnel

By | July 16, 2016

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

By | July 11, 2016

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

By | May 16, 2016

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 »