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Flash

Heightened dialogue on Two Pillars dominates Day 3 of 74th IFA Congress as panel deciphers Critical Mass

Day 2 at 74th IFA Congress focuses on Big Data - Taxation of Data Driven Business

OECD Tax Policy Director Pascal Saint-Amans announces he is stepping down

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

First on Taxsutra

ITAT Bar and Bench effusively praise outgoing Tribunal Vice-President Shri Pramod Kumar

First on Taxsutra

ITAT: Deletes TP-adjustment for write off of accrued interest and bad debts; No separate…

First on Taxsutra

ICAI releases Guidance Note on Tax Audit u/s.44AB; Incorporates guidance on reporting qua…

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Abnormal profit / supernormal profit companies
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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
Bright Line Test
business support services
Can add BEPS tag here if done for other such rulings though OECD not explicitly mentioned
Capacity Adjustment
capacity utilization
captive service provider
Commecial expediency / need
Commercial expediency
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Comparables
Concept of tested party
Condonation of delay due to covid
corporate guarantee
Corporate Guarantee & commission
COVID-19
Covid-19 delay in filing
CUP method
Definition of International transaction
Definitions
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Delayed pronouncement of order due to Covid-19 lockdown
Depreciation Adjustment
Design
Digital economy taxation
Disallowance u/s 40(a)(ia)
Domestic TP (Pre 2012 period)
DRP order binding on AO
E-assessment
export sales/ foreign exchange earnings
extraordinary event
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extraordinary event Retraction of comparables
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FAR
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Final order without draft order
Financial Transactions
Fluctuations in Foreign exchange
Foreign AE as tested party
FTS
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Functional profile - contract manufacturer
Functional similarity / dissimilarity - loss making companies
Functional similarity/ dissimilarity
General
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grant of opportunity of being heard
Granting opportunity of hearing
Guidelines
High end services
Impact of extraordinary event
impact on comparability due to merger, etc
Ind-AS
Intangibles
Inter-company balance payables
Interest on receivables
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Internal v/s external CUP
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international Transaction - guarantee
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  - FCCD Interest
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- Marketing intangible/ AMP adjustment
  - AMP-Intensity Adjustment
- Other intra-group services
- Profits attributable to PE
- Provision of Freight forwarding/ Logistics services
- Provision of Information Technology Enabled Services (ITeS)
- Provision of Investment advisory services
- Provision of marketing support services
- Provision of software development service
- Provision of software development service R&D filter
- Purchase of fixed asset
- Reimbursements
- Royalty
- Sale of Shares
- Transfer of business to AE
- Treatment of CCD/FCCD/OFCD
- Treatment of share application money as loan
International transactions - commission
International Transactions - Inter-company balance receivables
International Transactions - Marketing support services
Intra-group services
ITES and intra-group services
Limitation period
Loss making companies
margin computation
Methods
- Comparable Uncontrolled Price Method (CUP)
- Cost Plus Method
- Cost Plus Method more appropriate than TNMM
- CUP more appropriate than TNMM
- Profit Split Method
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- Ruling relevant for other method (6th method)
- TNMM more appropriate than CUP
- Transaction Net Margin Method
- Transactional Net Margin Method
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
Opportunity of hearing
Opportunmity of hearing
opporunity of hearing
Other
Other metho
Other method
Ownership of intangibles and comparability
passive income
Penalty
- Concealment Penalty
- Penalty for non-filing / delay in filing particulars, audit report
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
Provision of ITES
Provision of management services
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 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
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
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
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: Restricts TP-adjustment to value of business unit actually transferred, directs excluding assets…

Dec 06, 2022

Income tax Appellate Tribunal

ITAT: Holds TPO order barred by limitation, Expressions in statutes cannot be substituted by CBDT Circulars…

Dec 05, 2022

Income tax Appellate Tribunal

ITAT: Recharacterization of CCDs impermissible; Royalty payment @ 4% on sale at arm’s length

Dec 02, 2022

Income tax Appellate Tribunal

ITAT: Holds TPO’s order as barred by limitation, akin to Pfizer Healthcare ruling; Quashes final order

Dec 01, 2022

Trending Topics :

IFA Congress 2022
Corporate Guarantee
Intra group services
Outstanding receivables
MAP resolution

News

Around the World Latest

OECD recognises jurisdictions for speedy dispute resolution; India MAP stats ‘middling’

Nov 23, 2022

Around the World

Major jurisdictions agree to share information on digital economy, offshore financial assets

Nov 11, 2022

News

CBDT revises monetary limit for 'Dossier Cases'

Nov 08, 2022

News

CBDT releases FAQs to aid filing process for Form 3CEB

Oct 27, 2022

Experts' Corner

Expert Columns

Rahul K Mitra

Chartered Accountant

TP for Logistic Companies – Need to Look Beyond OP/VAE under TNMM

Nov 11, 2022

Expert Columns

Kedar Karve

Chartered Accountant

Section 92A - (1) & (2) - Associated or Dissociated?

Sep 30, 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: Rules on comparables in MSS & manufacturing; Orders denovo comparability analysis in trading…

Dec 06, 2022

Income tax Appellate Tribunal

ITAT: Remits comparability of company accepted by Dept earlier; Adopts interest ALP @ Swiss LIBOR+150bps

Dec 06, 2022

Income tax Appellate Tribunal

ITAT: Deletes AMP-adjustment absent existence of arrangement between assessee and AE; Applies rule of…

Dec 06, 2022

Income tax Appellate Tribunal

ITAT: Loss from eligible-units can be set off against TP-adjustment, 40(a)(i) disallowance; Dismisses…

Dec 05, 2022

Litigation Tracker

SC reserves judgment in SAP Labs case on comparables selection

Nov 15, 2022

SC: Disposes off certain SLPs tagged with SAP Labs; Cites settlement under VsV Act, low tax effect

Nov 14, 2022

SC: ASG Balbir Singh assails SAP Labs ruling, argues 'Comparables Selection' not mere mathematical…

Nov 10, 2022

SC: Entertains Revenue's SLP in Pfizer case on limitation period for TP order, Issues notice

Nov 09, 2022

Kaleidoscope

Reflections on Indian TP controversies – "Specified Domestic Transaction (SDT)…

Dec 02, 2022

Reflections on Indian TP controversies – "Depreciation Adjustment"

Nov 29, 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

Prevailing and Emerging Dilemmas in International Taxation (1st Edition) by Dr Parthasarathi Shome

First on Taxsutra

ITAT Bar and Bench effusively praise outgoing Tribunal Vice-President Shri Pramod Kumar

First on Taxsutra

ITAT: Deletes TP-adjustment for write off of accrued interest and bad debts; No separate…

First on Taxsutra

ICAI releases Guidance Note on Tax Audit u/s.44AB; Incorporates guidance on reporting qua…

Experts' Corner

Expert Columns

Rahul K Mitra

Chartered Accountant

TP for Logistic Companies – Need to Look Beyond OP/VAE under TNMM

Nov 11, 2022

Expert Columns

Kedar Karve

Chartered Accountant

Section 92A - (1) & (2) - Associated or Dissociated?

Sep 30, 2022

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

Prevailing and Emerging Dilemmas in International Taxation (1st Edition) by Dr Parthasarathi Shome

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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