Wednesday, August 5, 2020

Transfer Pricing

Split Verdict in Mitusubishi’s TDS Case: Delhi HC Refers the matter to Chief Justice [Read Judgment]

Due to difference of opinion between Justices S Muralidhar and Prathiba M Singh, the Delhi High Court, on Friday, has referred the Mitusubishi’s TDS case to the Chief Justice. Sogo Shosha Company Mitsubishi-India...

Govt Notifies Multilateral Competent Authority Agreement on Exchange of Country-by-Country Reports [Read Notification]

The Central Government notified the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country (CbC) reports in terms with the OECD recommendations. On May 2016, India had entered into an agreement on Mutual...

CBDT notifies Rule for Computing Interest Income for Secondary Adjustments under Transfer Pricing

The Central Board of Direct Taxes (CBDT) has amended the Income Tax Rules, 1962 and inserted Rule 10CB for computing interest income for secondary adjustments under Transfer Pricing. In transfer pricing parlance, a...

TPO cannot Go Beyond a Remand Order when such Remand was based on a Specific Finding: Delhi HC [Read Judgment]

In a recent ruling, the Delhi High Court found that the Transfer Pricing Officer (TPO) cannot go beyond a remand order when such remand was based on a specific finding. The division bench...

CBDT signs 3 more Advance Pricing Agreements; Total number of APAs reaches 120

The Central Board of Direct Taxes (CBDT) has started the year 2017 by entering into three unilateral Advance Pricing Agreements (APAs) today. The APA Scheme was introduced in the Income-tax Act in 2012...

AO is bound to give notice and Speaking Order before referring a matter to the TPO: Gujarat HC [Read Judgment]

In a recent decision, the division bench of the Gujarat High Court held that the Assessing Officer is liable to issue a Show Cause Notice and a speaking Order before referring a case...

India–USA Bilateral Competent Authority agrees to resolve 66 MAP cases relating to Transfer Pricing issues

India–USA Bilateral Competent Authority MAP/APA Meeting – Resolution of more than 100 cases under MAP and Agreement on terms and conditions of First ever Bilateral APA involving India and USA.The Bilateral Competent...

Transfer Pricing Proceedings can be initiated against the Company, If the directors held more than 20% Shares in an Associate Enterprise: Gujarat HC [Read...

The High Court of Gujarat while refusing to interfere with the transfer pricing proceedings initiated against a Company, observed that there is prima facie material to show that the directors of the...

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