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CBDT releases draft notification proposing new audit report Form for Trust/Institution
21 May 2019
Delhi HC remanded matter to TPO as ITAT didn’t discuss issue of functionality difference of assessee
20 May 2019
MAP between India-USA for determining ALP can also be applied for non-US based transactions: HC
16 May 2019
TNMM is MAM in ALP determination for contract manufacturer and exporter of components
15 May 2019
CBDT further deferred furnishing of GST & GAAR details in Form 3CD till March 31, 2020
Transfer Pricing Additional Documentation – Applicability, Forms, Due Dates and Penalties
Interest on outstanding receivable is an international taxation liable to TP adjustment
ALP of international transaction couldn't be determined by comparing price charged by other AE's
TDS certificate in Part B of Form 16 to be issued by downloading it from TRACES portal: CBDT
Companies affected by merger and acquisition not to be taken as comparables for TP study
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Issuance of corporate guarantee without incurring any cost wouldn't constitute international transaction
New filter for analysis if comparables couldn't be applied during appellate proceedings
CBDT to share data with GST dept. to trap tax evaders
AO couldn't raise the issue of determination of ALP at appellate stage for which no reference was made to TPO earlier
Internal CUP method can't be used for computing ALP if transactions with AEs are fundamentally of different nature
CBDT notifies agreement between India-USA on exchange of Country-by-Country reports
TPO erred in computing brand value of "Sony" on basis of Cos whose brands were abandoned: ITAT
Overview of Proposed Rule 10 for attribution of profit to PE
TPO couldn't deny working capital adjustment merely on ground that assessee was in service industry
Tax evasion of more than Rs. 1350 crore detected during search conducted on leading group of power sector in NCR
Company making losses for 3 consecutive years excluded from the list of comparables
Co. providing support services to its AE couldn't be compared with a Co. doing World Bank sponsored projects
Opinions
Introduction of methodology for attribution of income to business connections/ Permanent Establishment in domestic law
Deepa Nanda
Partner, Deloitte Haskins and Sells LLP
Cross-border transparency – adding dimensions to tax scrutiny
Rajiv Bajoria
Partner, Deloitte India
25 Best Income-tax Judgments in the year 2018
Editorial Team
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Featured Stories
25 Best Income-tax Judgments in the year 2018
A fraudulent company can't be chosen as comparable for TP study as its financial results aren't reliable
A software service provider can't be compared with a software developer for TP study
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Place of Effective Management In India – A Detailed Analysis
Transfer Pricing Additional Documentation – Applicability, Forms, Due Dates and Penalties
Overview of Singapore tax system
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Recruitment fee isn't taxable as 'FTS' under India-USA treaty: Delhi ITAT
Basis of cost for PLI under TNM method is ‘total operating cost’ and not its fraction such as ‘direct cost’
Accretion of Hyundai brand due to its usage on Cars manufactured in India isn’t brand promotion: ITAT
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