CBDT Transfer Pricing Instruction No.3/2003 dated 20.05.2003 | Latest Supreme Court Judgement
The Supreme Court has held in <strong>THE PRINCIPAL COMMISSIONER OF INCOME TAX-4, MUMBAI M/s. S.G. ASIA HOLDINGS (INDIA) PVT. LTD.</strong> that in view of the...
Draft assessment order is void if mandate of section 144C is not followed
The question considered is whether the AO erred in issuing a notice of demand under section 156 and a notice under section 274 read with...
Benchmarking Royalty Payments. ALP To Be Determined On CUP & TNMM Basis
In ACIT vs. Netafim Irrigation India Pvt Ltd the dispute arose on account of addition made towards transfer pricing adjustment to the arm’s length price...
Transfer Pricing Verdict Reg Existence of international transaction For AMP expenditure
The problem with the Revenue's approach is that it wants every instance of an AMP spend by an Indian entity which happens to use the...
ITAT Judgement On Transfer Pricing Of Cross Border AMP Expenditure
The transfer pricing adjustment is not expected to be made by deducing from the difference between the 'excessive' AMP expenditure incurred by the Assessee and...
Transfer pricing adjustment on account of arm’s length price of international transaction of AMP expenditure
The transfer pricing adjustment made by the ld TPO of Rs. 73,23,49,876/- on account of arm's length price of alleged international transaction of AMP expenditure...
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...
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...
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...