THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)] MINISTRY OF FINANCE (Department of Revenue) NOTIFICATION New Delhi, the 14th July, 2016 [INCOME TAX] S. O. 2425(E).—In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act,1961 (43 of 1961), read with proviso to sub-rule (7)… Read More »
The Transfer Pricing Officer used “segmental data” from several companies—data that did not form part of these companies’ audited accounts—in determining the arms’ length price. The taxpayer was not provided an opportunity to cross-examine the comparable companies’ authorised personnel who had provided the segmental data. The High Court found that in light of the tax… Read More »
Judgements on Transfer Pricing, International Tax and Domestic Tax Transfer Pricing – Page 2 International Tax – Page 42 Domestic Tax – Page 57 International transactions Cases 1 to 11 Permanent Establishment Cases 243 to 256 Income – Cases 321 to 330 Most Appropriate Method Royalty / Fees for technical services – Cases 257 to… Read More »
sections 92 to 92F in Chapter X of the Income-tax Act, 1961 INSTRUCTION NO.3/2016 [F.NO.500/9/2015-APA-II], DATED 10-3-2016 The provisions relating to transfer pricing are contained in sections 92 to 92F in Chapter X of the Income-tax Act, 1961. These provisions came into force w.e.f. Assessment Year 2002-2003 and have seen a number of amendments over… Read More »
Govt notifies tolerance limit of 1% and 3% under new Transfer pricing Notification no 86/2015/F No 500/1/2014/-APA/II Dated 29 oct 2015 Click to View
Transfer pricing guidelines notified by Govt