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Flash

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

CBDT notifies ITR Forms for AY 2022-23

CBDT signs 13 Bilateral APAs & 49 Unilateral APAs in FY 2021-22

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
Adjustment – Others
Adjustments
- Accounting Policies
- Capacity
- Credit period
- Depreciation
- Others
- Risk
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aggregation
ALP Adjustments
ALP computation
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- Benefit of +/- 5%
- Berry Ratio
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- Margin computation dispute
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  - Foreign exchange gain / loss
- Pass through costs
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  - Cash PLI
- Segmental results
- Single Year vs Multiple Year
- Suomoto adjustment by assessee
ALP computation - Entity level v. transaction level
ALP computation – adjustment
ALP computation-General
ALP Determination
AMP Adjustment
Appellate Authority - Powers, Jurisdiction etc.
- Admission of additional evidence
- Admission of additional ground
- DRP / CIT(A) order binding on AO
- Miscellaneous Application / Miscellaneous Petition
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- Power to remand matter back to AO/TPO
- Scope and powers
Appellate Authority - Powers, Jurisdiction etc.
Appellate procedures
Applicability of TP-provisions to income covered under the Tonnage Tax Scheme
Arms length principle under tax holiday provisions
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  - Exclusion of comparable due to unreliable financial results
  - Fluctuations in profit margins & comparability
  - Govt. owned undertakings
  - High end services vis--vis Low end services
  - High end services vis-à-vis Low end services
  - Impact on comparability of events like merger, acquisition, spin off
  - KPO vs BPO
  - Loss Making comparables
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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
business support services
Capacity Adjustment
capacity utilization
captive service provider
Commecial expediency / need
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Concept of tested party
corporate guarantee
Corporate Guarantee & commission
COVID-19
CUP method
Definitions
- Associated Enterprise
- International Transaction
Delayed pronouncement of order due to Covid-19 lockdown
Depreciation Adjustment
Design
Domestic TP (Pre 2012 period)
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E-assessment
export sales/ foreign exchange earnings
extraordinary event
extraordinary event Retraction of comparables
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
Functional Classification
- Contract Manufacturing
- Contract R&D
- Distributor
- Retail traders
- Sogo shosha (acting as trading intermediaries)
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 on comparability due to merger, etc
Ind-AS
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 - Inter-company balance receivables
International Transactions - Marketing support services
Intra-group services
Limitation period
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
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
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 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
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

Income tax Appellate Tribunal Latest

ITAT: Calls-out assessee's flip-flop between CUP and TNMM, Directs making of crystal-clear choice;…

Jun 23, 2022

Income tax Appellate Tribunal

ITAT: Rejects characterization of optionally convertible debenture as debt; Deletes ALP-adjustment

Jun 22, 2022

Income tax Appellate Tribunal

ITAT: Upholds final assessment order basis dispatch date despite different CPC date, Refers to pre-2018…

Jun 21, 2022

Income tax Appellate Tribunal

ITAT: Rejects LIBOR base for benchmarking outstanding AE-receivables on grounds of profit shifting to AE

Jun 21, 2022

Trending Topics :

Union Budget 2022
Budget 2022
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News

News Latest

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

Jun 18, 2022

Around the World News

OECD releases fourth batch of TP country profiles for four new countries; Increases participation score to 73…

Jun 14, 2022

News

7 Key Takeaways from Updated MAP Guidance

Jun 13, 2022

CBDT Corner

CBDT issues Notifications to facilitate Faceless Assessments, effective from Jun 6

Jun 11, 2022

Experts' Corner

Expert Columns

Ajay Kering

Partner at Ahuja Valecha & Associates LLP

Extension of Safe Harbour Rules to AY 2022-23: Is it Harbouring Industry Expectations?

Jun 20, 2022

Expert Columns

Chetan Rajput

Partner, Ernst & Young LLP

Regulations for Related Party Transactions: Different yet Similar

Jun 16, 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: Confirms deletion of TP-adjustment qua outstanding AE receivables; Follows Kusum Healthcare

Jun 24, 2022

Income tax Appellate Tribunal

ITAT: Rules on comparables for Citrix's SWD, ITeS segments, allows working capital adjustment

Jun 24, 2022

Income tax Appellate Tribunal

ITAT: Rules on comparables in SWD-service segment; Excludes Thirdware Solutions as no segmental results…

Jun 23, 2022

Income tax Appellate Tribunal

ITAT: Deletes ALP-adjustment on interest free optionally convertible debentures; Follows earlier-order

Jun 23, 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 : Berry Ratio

Jun 20, 2022

Reflections on Indian TP controversies – Assessment post merger or amalgamation

Jun 17, 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

Ajay Kering

Partner at Ahuja Valecha & Associates LLP

Extension of Safe Harbour Rules to AY 2022-23: Is it Harbouring Industry Expectations?

Jun 20, 2022

Expert Columns

Chetan Rajput

Partner, Ernst & Young LLP

Regulations for Related Party Transactions: Different yet Similar

Jun 16, 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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