Introduction of Range Concept: Arun Jaitley in the Budget 2014, introduced range concept and allowed the use of multiple year data in order to align the transfer pricing practices to the transfer…
Category: Transfer Pricing
Sec 92CE: Secondary Adjustment In Transfer Pricing
Sec 92CE: Secondary Adjustment: “Primary adjustment” to a transfer price means the determination of transfer price in accordance with the arm’s length principle resulting in an increase in the total income or…
Section 92CC: Advance pricing Agreement (APA)
Advance Pricing Agreement: The Central Board of Direct Tax (CBDT) with the approval of Central Govt, may enter into Advance pricing Agreement with any person for determination: (a) Arm’s Length Price or…
Notification U/s 92C(2) Of Tolerance Limit For ALP Determination
As per the provision of section 92C(2) of Income Tax Act, 1961, If more than one price is determined as per the most appropriate method the Average (arithmetic mean) of such price…
Sec 286:Furnishing Of Report In Respect Of An International Group
If parent entity of the international group / alternate reporting entity is resident in India shall be required to furnish Country-by country report (if the group revenue as per Consolidated financial statement…
Compliance Procedure Under Advance Pricing Agreement
Compliance Procedure Under Advance Pricing Agreement Person proposing to enter into Advance pricing agreement shall make an application to DGIT (International Taxation) requesting for pre-filing consultation. The Pre-filing consultation shall determine suitability…
Section 92CD: Effect Of Advance Pricing Agreement
Section 92CD: Effect of Advance Pricing Agreement: Where prior to the date of entering Advance Pricing Agreement, any return of income has already been furnished for any Previous year to which Advance…
Section 92CA – Reference To Transfer Pricing Officer [Amended]
Section 92CA: Reference to Transfer pricing Officer: If Assessing Officer considers it necessary, he may refer the computation of Arm’s length price to Transfer pricing Officer, with previous approval of Commissioner of Income…
Sec 92C(3): Determination Of Arm’s Length Price By Assessing Officer
Section 92C(3): Determination Of Arm’s Length Price By Assessing Officer: In the following cases Arm’s length price shall be computed by Assessing Officer Assessee fails to compute Arm’s length price as per…
Country-by-country Report: Reporting Requirements Of MNEs
Country-by-country Report: Reporting Requirements Of MNEs: Under BEPS Action 13, all large multinational enterprises (MNEs) are required to prepare a country-by-country (CbC) report with aggregate data on the global allocation of income,…
Sec 92D: Maintenance Of Information & Documents
Maintenance Of Information & Documents: Section 92D imposes responsibility on any entity, which is a constituent entity of an international group to keep and maintain the requisite information and document in respect…
Sec 94A:Transaction With Person Located In Notified Jurisdictional Area
Special Provision In Respect Of Transaction With Person Located In NJA: CG may notify any country or territory outside India to be a Notified Jurisdictional Area (NJA). If Assessee enters into transaction…
Sec 92BA: Specified Domestic Transactions
Sec 92BA: Specified Domestic Transactions Any of the following transactions where the aggregate value of such transactions in the Previous year is more than 20 crs , then it is treated as…
Maintenance And Furnishing Of Master File In Transfer Pricing
Maintenance And Furnishing Of Master File: Persons required to keep and maintain the information and documents: [Rule 10DA]: Every person, being a constituent entity of an international group shall- (i) if the…
Section 93: Transfer Of Income/Assets To Non-residents
Transfer Of Income/Assets To Non-residents Section 93 covers transactions which are designed to avoid tax liability by way of transfer of asset to non-resident persons. This section also covers variety of transactions…
