Tag: Transfer Pricing
High Court upheld inclusion and exclusion of comparables by TPO based on filters of losses, declining sales, segment reporting employee cost etc. ABCAUS Case Law Citation: ABCAUS 2280 (2018) (04) HC The appellant assessee had filed the instant appeal under Section 260A of the Income Tax Act, 1961 …
Transfer Pricing Documentation and Country-by-Country Reporting. Rules 10DA, 10DB and form nos. 3CEBA to 3CEBE proposed laying down guidelines for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country report. Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes …
Rule 10CB-Computation of interest income under secondary adjustments. Time limit for repatriation of excess money u/s 92CE (2) to be 90 days MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) Notification No. 52/2017 New Delhi, the 15th June, 2017 G.S.R. 590(E).— In exercise of the …
In a recent judgment, ITAT Delhi has held that Knowledge Process Outsourcing Services (KPO Services) provider could not be be considered as a comparable for benchmarking international transactions entered into by an entity rendering business process outsourcing (BPO) services including collections/call centre services and other back office support services for …
Comptroller and Auditor General (C&AG) Report No. 03 of 2016 for the year ended March 2015 on Compliance Audit on Direct Tax Department Union Government tabled on 11-03-2016. As per the report the instances mentioned are those which came to notice in the course of test audit for …
CBDT Revised Guidelines for Implementation of Transfer Pricing Provisions Instruction No. 03/2016 Instruction No. 3/2016 F. No. 500/9/2015-APA-IIGovernment of IndiaMinistry of FinanceDepartment of RevenueCentral Board of Direct TaxesForeign Tax and Tax Research Division-IAPA-II Section New Delhi, dated 10th March, 2016 Subject: Guidelines for Implementation of Transfer Pricing Provisions-Replacement …
