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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: 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…

First on Taxsutra

ITAT: Refuses to consider credit-period agreed between assessee & AE while benchmarking delayed…

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Abnormal profit / supernormal profit companies
acquisition
Additional ground
Adjustment - Working Capital
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Adjustments
- Accounting Policies
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aggregation
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ALP Adjustments
ALP computation
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  - Foreign exchange gain / loss
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ALP computation - Entity level v. transaction level
ALP computation – adjustment
ALP computation-General
ALP Determination
AMP Adjustment
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Appellate Authority - Powers, Jurisdiction etc.
- Admission of additional evidence
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Appellate procedures
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  - High end services vis-à-vis Low end services
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  - Ownership of Intangible & comparability
  - Relevance of product similarity for comparability
  - Secret comparables
  - Software product companies vs. Software service companies
  - Super normal profit comparables
- Industry Rates
- Internal vs. External comparables
- Location Saving / Locational Advantage
- Relevance of FAR
- Reliance on Government Guidelines (RBI, FIPB, Commerce Ministry Press Notes, etc)
- Rulings having discussion on comparability of specific companies
- Separate and combined transactions
- Updation of comparables
- Use of Customs Data
benchmarking - Captive service provider
benchmarking - Controlled transaction as comparable
Benchmarking - royalty
Benchmarking-Companies held to functionally similar
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
Commercial expediency test
Comparables
Concept of tested party
corporate guarantee
Corporate Guarantee & commission
COVID-19
Covid-19 delay in filing
CUP method
Definition of International transaction
Definitions
- Associated Enterprise
- International Transaction
Delayed pronouncement of order due to Covid-19 lockdown
Depreciation Adjustment
Design
Digital economy taxation
Domestic TP (Pre 2012 period)
DRP order binding on AO
E-assessment
export sales/ foreign exchange earnings
extraordinary event
extraordinary event Retraction of comparables
Extraordinary events impacting profitability
FAR
FAR Analysis
Filters - Impact on comparability of events like merger
Filters - RPT
Filters - spin off
Filters – Others
Final order without draft order
Financial Transactions
Fluctuations in Foreign exchange
Foreign AE as tested party
FTS
Functional Classification
- Contract Manufacturing
- Contract R&D
- Distributor
- Retail traders
- Sogo shosha (acting as trading intermediaries)
Functional profile - contract manufacturer
Functional similarity / dissimilarity - loss making companies
Functional similarity/ dissimilarity
Govt company
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
Internal transaction
Internal v/s external CUP
Internal v/s external TNMM
international Transaction - guarantee
International transaction - Outstanding payable
International transactions
- Commission
- Cost Allocations
- Cost Sharing Arrangements
- Deemed International transactions
- Employee Stock Option Plans
- Guarantee
- Intangibles - Trademarks, Copyrights, etc.
- Inter-company balance receivables
- Interest
  - FCCD Interest
- Issue of shares
- Loan
- Management Charges
- 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
- Resale Price Method
- Ruling relevant for other method (6th method)
- TNMM more appropriate than CUP
- Transaction Net Margin Method
- Transactional Net Margin Method
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 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
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: Non-service of DRP’s direction doesn't vitiate final assessment-order; Dismisses Cummins India…

Oct 03, 2022

Income tax Appellate Tribunal

ITAT: Adjudicates on aggregation of international transactions; Payment of Royalty cannot be clubbed with…

Sep 30, 2022

Income tax Appellate Tribunal

ITAT: Allows assessee’s appeal; Directs AO to consider assessee’s modified return giving effect to APA

Sep 28, 2022

High Court

HC: Refuses to interfere with ITAT order excluding functionally dissimilar comparables sans perversity

Sep 27, 2022

Trending Topics :

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

News

Around the World Latest

US Tax Court issues supplemental opinion, holds CUT not best method to determine ALP in Medtronic’s case

Sep 20, 2022

News

EU Directives on Pillar Two & DEBRA, Proposals on Unshell & SAFE mark the Final Day of 74th IFA…

Sep 09, 2022

News

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

Sep 08, 2022

Around the World

US Court of Appeal points out IRS’s limited discretion in cancelling APAs; Provides penalty relief to Eaton…

Sep 07, 2022

Experts' Corner

Expert Columns

Kedar Karve

Chartered Accountant

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

Sep 30, 2022

Expert Columns

Tejas Dharwadkar

Partner, Unicus Risk Advisors LLP

Pass through Costs: Will it “Pass” the Test of Functional Dilemma? - Part II

Sep 29, 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: Excludes comparables for turnover over 200Cr for EDS provider, remits working capital adjustment

Oct 04, 2022

Income tax Appellate Tribunal

ITAT: Excludes 9 comparables having turnover more than Rs. 200 crores; Remits margin computation plea

Oct 04, 2022

Income tax Appellate Tribunal

ITAT: Deletes TP-adjustment qua SDTs; Attributes reason to omission of clause (1) of Sec.92BA

Oct 04, 2022

Income tax Appellate Tribunal

ITAT: Remits assessee’s appeal against final-assessment order despite assessee's non-appearance before…

Oct 03, 2022

Litigation Tracker

HC: Admits Revenue’s appeal; Frames 4 substantial questions of law on RPT filter, working capital adjustment…

Sep 16, 2022

HC: Admits Revenue’s appeal; Frames 4 substantial questions of law on working-capital adjustment,…

Sep 14, 2022

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

Kaleidoscope

Reflections on Indian TP controversies: Reference to TPO

Sep 30, 2022

Reflections on Indian TP controversies – "Intra-Group Services"

Sep 12, 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: 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…

First on Taxsutra

ITAT: Refuses to consider credit-period agreed between assessee & AE while benchmarking delayed…

Experts' Corner

Expert Columns

Kedar Karve

Chartered Accountant

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

Sep 30, 2022

Expert Columns

Tejas Dharwadkar

Partner, Unicus Risk Advisors LLP

Pass through Costs: Will it “Pass” the Test of Functional Dilemma? - Part II

Sep 29, 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

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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