Tag: Transfer Pricing
Arms Length Price of intra group management fee paid determined Nil by TPO upheld as there was no evidence on record to prove rendition of services. ABCAUS Case Law Citation: ABCAUS 3002 (2019) (06) ITAT Important Case Laws Cited/relied upon by the parties: 3M India Ltd vs. Addl. …
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 …
