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Flash

Directorate Systems reduces time-limit for e-verification, ITR-V submission to 30 days from 120 days

DGIT(Sys.) specifies various forms/returns for mandatory electronic furnishing

CBDT extends applicability of Safe Harbour Rules to AY 2022-23

7 Key Takeaways from Updated MAP Guidance

CBDT Member Mrs Sangeeta Singh to take additional charge as Chairperson

CBDT notifies ITR-U for filing Updated Return under Sec.139(8A)

CBDT revises instruction for grievances against high-pitched assessments in light of faceless regime

HC: Madras HC dismisses Revenue's writ appeal on limitation period for TPO's order

CBDT notifies Rules & Scheme to operationalise Dispute Resolution under Sec.245MA

OECD releases Draft Rules for Domestic Legislation on Scope under Pillar One, Amount A; Invites public comments by Apr 20

First on Taxsutra

ITAT SB concludes hearing on whether transactions between HO and PE qualify as “international…

First on Taxsutra

CBDT's Interim Action Plan for FY 2022-23 - Reassessments, Penalty proceedings & Refund…

First on Taxsutra

ITAT Special Bench: Hears both parties on interpretation of "paid" under India-Cyprus…

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acquisition
Adjustment - Working Capital
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benchmarking - Captive service provider
benchmarking - Controlled transaction as comparable
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International transactions
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  - FCCD Interest
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- Other intra-group services
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Intra-group services
ITES and intra-group services
Limitation period
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Methods
- Comparable Uncontrolled Price Method (CUP)
- Cost Plus Method
- Cost Plus Method more appropriate than TNMM
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- Profit Split Method
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- Ruling relevant for other method (6th method)
- TNMM more appropriate than CUP
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O/s receivables
omparable Uncontolrred Price Mtehtod
Operating / Non-operating costs
Operating Income and Expenses
Operating/Non-operating Income and Expenses
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opporunity of hearing
Other
Other metho
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Ownership of intangibles and comparability
passive income
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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 the appellate authority
Powers of the assessing authority
Profit attribution to PE
Provision of ITES
Provision of software development services
PSM
reference to APA
Reference to Safe Harbour Rules
Reimbursements Other intra-group services
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
rule on consistency
Rulings having a discussion on comparability of specific companies
Rulings having discussion on comparability of specific comparables
Rulings having discussion on comparaiblity of companies
Segmental
Segmental details
Selection of Comparables
Separate benchmarkin
Separate v/s aggregate benchmarking
Settlement Commission
shareholder services
Software development services
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
TP applicablity
TP assessment
TP Assessment & litigation - procedural issues
TP Assessment & litigation – time limit / notices
TP assessment procedural issues
TP benchmarking
TP Benchmarking - comparables
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
Turnover filter
unreliable financials
validity of Assessmen
working capital adjustment
working-capital adjustment

Number

Applevel

Year

Rulings

Supreme Court Latest

SC: Dismisses Revenue’s SLP against HC-order holding Sub-sections (1) & (2) of Sec. 92A interlinked

Aug 09, 2022

Income tax Appellate Tribunal

ITAT: Notes insufficient proof of intra-group service, Remits for determination on rendition and MAM to…

Aug 03, 2022

Income tax Appellate Tribunal

ITAT: Factors assessee's risky BBB credit rating to determine interest ALP qua NCDs, Deletes TP-…

Aug 01, 2022

Income tax Appellate Tribunal

ITAT: Deletes notional interest imputed on outstanding AE receivables qua Sony Pictures

Aug 01, 2022

Trending Topics :

Faceless assessment
International tax
Vivad Se Vishwas Scheme
Union Budget 2022
Budget 2022

News

Around the World Latest

ATO releases Consultation paper on thin capitalisation, royalty and intangibles deduction rules; Invites…

Aug 10, 2022

CBDT Corner Circulars/Notificati

Directorate Systems reduces time-limit for e-verification, ITR-V submission to 30 days from 120 days

Aug 01, 2022

News

ICAI releases updated Exposure Draft of Sec.92E Guidance Note with Finance-Act 2022 amendments

Jul 26, 2022

APA Space Circulars/Notifications News

DGIT(Sys.) specifies various forms/returns for mandatory electronic furnishing

Jul 18, 2022

Experts' Corner

Expert Columns

Rahul K Mitra

Chartered Accountant

Transfer Pricing in India – Obsession With The Term, “International Transaction”

Aug 10, 2022

Expert Columns

Paresh Parekh

Partner, Ernst & Young LLP

Netherlands - New TP Decree and MNCs: Shaking Up The Traditional Structures?

Jul 19, 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

Updates

Income tax Appellate Tribunal Latest

ITAT: Allows Sec 80IA deduction for profit of power division; Follows assessee’s earlier order

Aug 10, 2022

Income tax Appellate Tribunal

ITAT: Allows deduction on account of management fee paid; Considers assessee’s evidences proving receipt of…

Aug 10, 2022

Income tax Appellate Tribunal

ITAT: Remits ALP-computation; TPO's wrong characterization of services prejudices ALP-determination

Aug 10, 2022

Income tax Appellate Tribunal

ITAT: Rules on comparables; Remits issue of working capital adjustment and outstanding receivables

Aug 10, 2022

Litigation Tracker

HC: Adjudicates on assessee’s writ petition raising TP grounds; Extends interim relief

May 17, 2022

HC: Grants stay on final assessment order passed sans draft assessment order; Issues notice to Revenue

May 11, 2022

ITAT SB concludes hearing on whether transactions between HO and PE qualify as “international transactions”…

May 09, 2022

SC concludes hearing in reassessment controversy, reserves judgment

Apr 20, 2022

Kaleidoscope

Reflections on Indian TP controversies- Foreign Exchange Earnings Filter

Jul 29, 2022

Reflections on Indian TP controversies – "Concealment penalty

Jul 06, 2022

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

ITAT SB concludes hearing on whether transactions between HO and PE qualify as “international…

First on Taxsutra

CBDT's Interim Action Plan for FY 2022-23 - Reassessments, Penalty proceedings & Refund…

First on Taxsutra

ITAT Special Bench: Hears both parties on interpretation of "paid" under India-Cyprus…

Experts' Corner

Expert Columns

Rahul K Mitra

Chartered Accountant

Transfer Pricing in India – Obsession With The Term, “International Transaction”

Aug 10, 2022

Expert Columns

Paresh Parekh

Partner, Ernst & Young LLP

Netherlands - New TP Decree and MNCs: Shaking Up The Traditional Structures?

Jul 19, 2022

Global TP Battleground

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

Apr 27, 2022

‘Loan Notes’ & Transfer Pricing: Recent Australian Transfer Pricing Ruling…

Jan 25, 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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