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Flash

Copy of Finance Bill, 2023, as passed by Parliament

CBDT signs record 21 APAs in a single day

20 Key Takeaways from the Amendments made in the Finance Bill, 2023

ITAT: Holds sale of 3.35% shares of United Spirits be subject to ALP determination; Reads 92A(2) "literally"

Finance Bill, 2023 - Clinical Analysis of 120+ Direct Tax Amendments

Finance Bill proposes for inventory valuation by Dept. nominated Cost Accountant

Finance Bill proposes to tax Market Linked Debentures transfer as STCG

Finance Bill expands scope of capital gains w.r.t. intangible assets/ rights with indeterminate cost

Finance Bill addresses double non-taxation of certain distributions made by REIT & InvIT

Finance Bill 2023 proposes to bring Cooperative Societies under the SDT regime

First on Taxsutra

Copy of Finance Bill, 2023, as passed by Parliament

First on Taxsutra

20 Key Takeaways from the Amendments made in the Finance Bill, 2023

First on Taxsutra

Transaction Square Opens Family Office Vertical, Eyes IPO

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5% tolerance range
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- Rulings having discussion on comparability of specific companies
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benchmarking - Captive service provider
benchmarking - Controlled transaction as comparable
Benchmarking - royalty
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Benefit test
BEPS
BLT rule of Consistency
Bright Line Test
business support services
Can add BEPS tag here if done for other such rulings though OECD not explicitly mentioned
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capacity utilization
captive service provider
Commecial expediency / need
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corporate guarantee
Corporate Guarantee & commission
COVID-19
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Delayed pronouncement of order due to Covid-19 lockdown
Depreciation Adjustment
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Digital economy taxation
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DRP order binding on AO
E-assessment
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export sales/ foreign exchange earnings
extraordinary event
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extraordinary event Retraction of comparables
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impact on comparability due to merger, etc
Ind-AS
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international Transaction - guarantee
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  - FCCD Interest
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- Loan
- Management Charges
- Marketing intangible/ AMP adjustment
  - AMP-Intensity Adjustment
- Other intra-group services
- Profits attributable to PE
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- Provision of Information Technology Enabled Services (ITeS)
- Provision of Investment advisory services
- Provision of marketing support services
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- Provision of software development service R&D filter
- Purchase of fixed asset
- Reimbursements
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- Treatment of share application money as loan
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Intra-group services
ITES and intra-group services
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margin computation
Methods
- Comparable Uncontrolled Price Method (CUP)
- Cost Plus Method
- Cost Plus Method more appropriate than TNMM
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- Ruling relevant for other method (6th method)
- TNMM more appropriate than CUP
- Transaction Net Margin Method
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Notice issued on non existing entity/person
O/s receivables
OECD
omparable Uncontolrred Price Mtehtod
Operating / Non-operating costs
Operating Income and Expenses
Operating/Non-operating Income and Expenses
Operating/Non-operating Income and Expenses –foreign exchange
Opportunity of being heard
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Opportunmity of hearing
opporunity of hearing
Other
Other metho
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Outstanding receivables
Ownership of intangibles and comparability
passive income
Penalty
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Penalty for non-filing / delay in filing particulars
PLI computation
Powers / Jurisdiction of Appellate Authority
- Condonation of delay
Powers and jurisdiction of AO
Powers of assessing authorities
Powers of the appellate authority
Powers of the assessing authority
Profit attribution to PE
Profit level Indicator
Provision of ITES
Provision of management services
Provision of MSS
Provision of software development services
Provision of SWD services
PSM
reference to APA
Reference to Safe Harbour Rules
Reimbursements Other intra-group services
Relevance of FAR analysis
Relevance of Government Guidelines (ICAI)
Relevance of international material
Relevance of RBI guidelines etc
Reliance on Governmetn Guidel
Reliance on Governmetn Guidelines
reliance on international guidelines
Reliance on OECD Guidelines
Remand
remand for consideration
Remand for fresh
Remand of fresh consideration
rendering of ITES
Revisionary power
Risk Adjustment
RPM
RPT filter
rule on consistency
Ruling relevant
Ruling relevant for other method
Rulings having a discussion on comparability of specific companies
Rulings having discussion on comparability of specific comparables
Rulings having discussion on comparaiblity of companies
Safe Harbour
Scope & powers
Segmental
Segmental details
Selection of Comparables
Separate benchmarkin
Separate v/s aggregate benchmarking
Settlement Commission
shareholder services
Software development services
Software product v. software development
Specified domestic transaction (SDT)
spin off, employee cost
submission of additinal evidence
Substantial question of law on comparables
Suomoto adjustm
T Srinivasa Rao
Time limit for completion of assessment
TNMM
TNMM over CUP
TP adjustment
TP adjustment & MAT provisions
TP Adjustment - credit period
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TP assessment
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TP benchmarking
TP Benchmarking - comparables
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Transfer pricing
Transfer Pricing adjustments
Transfer Pricing applicability
- Base erosion plea u/s 92(3)
- Pre-2002 provisions
- Pre-condition for invoking Chapter X & Intent
- Reference to TPO
- TP applicability & existence of income/ taxable income
Transfer Pricing assessments
- Aggregation of Transactions
- assessment post merger/amalgamation
- Consideration of APA/MAP
- Final assessment without draft order
- Granting opportunity of being heard
- Miscellenous petition / application
- Powers / Jurisdiction of Assessing Authorities
  - Adjustments by TPO on issues not referred by AO
  - Questioning commercial expediency / Proving Benefit test
  - TPOs order binding on AO
- Reassessment u/s 147 in reference to transfer pricing provisions
- Relevance of International Material (OECD Guidelines, International case laws)
  - Reference to BEPS Action Plans
- Remand for fresh consideration
- Resolution under MAP/APA
- Retraction of comparables
- Revision u/s 263 w.r.t transfer pricing
- Right of assessee to seek correction of own mistakes
- Right to contest comparable when not contested before earlier forum
- Rule of Consistency
- Secondary adjustment
- Stay of demand
- Threshold limit of Rs 5 crores
- Time limit for completing the assessment
- TP and Search Proceedings
Treatment of CD/FCCD/OFCD
Treatment of NCDs
Turnover filter
unreliable financials
validity of Assessmen
working capital adjustment
working-capital adjustment

Number

Applevel

Year

Rulings

Income tax Appellate Tribunal Latest

ITAT: Accepts assessee’s inter-unit electricity transmission cost qua 80-IA eligible unit, citing assessee’s…

Mar 27, 2023

Income tax Appellate Tribunal

ITAT: Upholds customs data to be more reliable under CUP; Relies on precedents and OECD commentary

Mar 20, 2023

Income tax Appellate Tribunal

ITAT: Holds assessment void-ab-initio absent valid reference to TPO

Mar 17, 2023

Foreign Court

FC: US Tax Court upholds TP adjustment qua trademark royalty; Rules on validity of foreign legal…

Mar 03, 2023

Trending Topics :

Section 194S
MFN Clause
Reassessment
IFA Congress 2022
Corporate Guarantee

News

News Latest

Copy of Finance Bill, 2023, as passed by Parliament

Mar 27, 2023

CBDT Corner News

CBDT signs record 21 APAs in a single day

Mar 25, 2023

News

20 Key Takeaways from the Amendments made in the Finance Bill, 2023

Mar 24, 2023

News

CBDT issues press release regarding survey on 'Prominent' International Media Co; Highlights TP…

Feb 17, 2023

Experts' Corner

Expert Columns

CA Akshay Kenkre

Founder, TransPrice Tax Advisors LLP

Angel Tax - Implications on Transfer Pricing

Feb 07, 2023

Expert Columns

Bhavesh Dedhia

Partner, Global Transfer Pricing, B S R & Company

TP Report Timeline Reduction in Budget – Implication

Feb 07, 2023

Tax Ring

Mumbai ITAT's judgment in Gemological Institute of America Inc case - ...
May 12, 2021
CBDT's Revision of Master File and CbCR Regime - Does it Pave Way for ...
Apr 07, 2021

Updates

Income tax Appellate Tribunal Latest

ITAT: Rejects segmental allocation of employee cost citing maintenance of separate records; Rules on…

Mar 30, 2023

Income tax Appellate Tribunal

ITAT: Upholds fixing guarantee commission @0.35%, internal CUP qua brokerage, levying mark-up on expense…

Mar 30, 2023

Income tax Appellate Tribunal

ITAT: Rules on comparables, remits margin computation for captive service provider; Follows Precedents

Mar 30, 2023

Income tax Appellate Tribunal

ITAT: Deletes BLT based AMP adjustment in RayBan's case in second round of proceedings

Mar 29, 2023

Litigation Tracker

HC: Hears Revenue’s appeal against ITAT-order holding TPO-reference not required, Schedules hearing in April…

Jan 19, 2023

SC: Issues notice w.r.t Revenue’s SLP against HC-order holding TPO’s order as barred by limitation

Dec 22, 2022

SC: Condones delay, issues notice in Revenue’s SLP against HC-order in case of Roca Bathroom Products

Dec 16, 2022

HC: Sets aside reference to TPO and CIT’s approval thereof; Directs for fresh order, keeps writ points open…

Dec 14, 2022

Kaleidoscope

Reflections on Indian TP controversies – "TNMM more appropriate than CUP”

Mar 24, 2023

Reflections on Indian TP controversies - "Profits attributable to PE"

Mar 09, 2023

BEPS

US, UK, Austria, France, Italy & Spain strike transitional Compromise over Unilateral Measures with tax…
Oct 22, 2021
OECD releases fourth peer-review report of BEPS AP 13, Acknowledges India's EOI-processes consistent…
Oct 18, 2021

Taxsutra TV

Mr. Vijay Iyer bats for a more effective dispute resolution mechanism, easier compliances, effective tax rates

Jan 30, 2022

Rishabh Kumar Sawansukha, Vice President – Taxation, Snapdeal

Nov 19, 2015

Book Reviews

Tangible Guide to Intangibles

Transfer Pricing Demystified

Taxsutra Insights

Finance Bill, 2022 - Direct Tax Rulings Impacted

Feb 04, 2022

Key Developments in OECD/G20 BEPS Inclusive Framework Statement

Oct 11, 2021

First on Taxsutra

Copy of Finance Bill, 2023, as passed by Parliament

First on Taxsutra

20 Key Takeaways from the Amendments made in the Finance Bill, 2023

First on Taxsutra

Transaction Square Opens Family Office Vertical, Eyes IPO

Experts' Corner

Expert Columns

CA Akshay Kenkre

Founder, TransPrice Tax Advisors LLP

Angel Tax - Implications on Transfer Pricing

Feb 07, 2023

Expert Columns

Bhavesh Dedhia

Partner, Global Transfer Pricing, B S R & Company

TP Report Timeline Reduction in Budget – Implication

Feb 07, 2023

Global TP Battleground

UK ruling on Intra-group Loans issued for Acquisition purposes - An Analysis

Sep 28, 2022

French Tax Authorities raising non-vanilla questions around Pricing of…

Apr 27, 2022

Tax Ring

Mumbai ITAT's judgment in Gemological Institute of America Inc case - ...
May 12, 2021
CBDT's Revision of Master File and CbCR Regime - Does it Pave Way for ...
Apr 07, 2021

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