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Transfer Pricing September 20, 2018

ALP adjustment Of AMP Expenditure On Bright Line Test Is Not Permissible

The TPO, while framing the order u/s 92CA(3) of the Act, was well aware with the decision of the Hon’ble jurisdictional High Court of Delhi in the case of Sony Ericcson Mobile Communication India Pvt Ltd reported at 276 CTR 97, and therefore, it cannot be said that the TPO was not aware that the Bright Line test has been discarded by the Hon’ble High Court of Delhi

Transfer Pricing January 14, 2018

Guide To Transfer Pricing Law In India

Guide to transfer pricing law in India with methods of determining ALP, APA scheme, documentation procedures, Landmark cases and latest judgements on transfer pricing controversies

Income-tax January 12, 2018

Taxability of off the shelf software as ‘Royalty’ under the income-tax Act and DTAA

In this article we will consider whether the amounts received on account of supply of off the shelf software can be taxed as ‘royalty’ under Section 9(l)(vi) of the Act and Article 12 of the Double Taxation Avoidance Agreement between India and Ireland (‘India- Ireland Tax Treaty)