The tax dispute resolution mechanism under transfer pricing in India consists of the following forums : – DRP or Appeal before the Commissioner of Income
OBJECTIVE OF INTRODUCTION OF SECTION 94A Discourage assessees from entering into transactions with persons located in countries or territories which do not exchange tax information
Meaning of Mutual Agreement Procedure (MAP) Mutual Agreement Procedure (MAP) is a special facilitative procedure set out in various tax treaties that allows designated government
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SECONDARY ADJUSTMENT – SECTION 92CE The Finance Act, 2017 has inserted the provision of “Secondary adjustment” to reflect that the actual allocation of profits between
Transfer Pricing Assessment Procedure in India APPEAL PROCEDURE POWER OF ASSESSING OFFICER TO DETERMINE THE ARM’S LENGTH PRICE Section 92C(3) gives power to AO to
SAFE HARBOUR RULES FOR INTERNATIONAL TRANSACTION SAFE HARBOUR RULES – CONTRACT R & D SERVICES SAFE HARBOUR RULES FOR INTERNATIONAL TRANSACTION SAFE HARBOUR RULES –
SAFE HARBOUR RULES FOR SPECIFIED DOMESTIC TRANSACTION CBDT vide Notification No. 11/2015 dated 04.02.2015 in exercise of the powers conferred by section 92CB and 92D,
TRANSFER PRICING ON INCOME FROM DOMESTIC RELATED PARTY TRANSACTIONS – [SECTION 92(2A)] Specified Domestic Transactions were covered under transfer pricing regime to – Determine income
OBJECTIVES OF COUNTRY BY COUNTRY REPORTING The key objectives of the Country by Country Reporting (CbCR) are as under: – The Report requires taxpayers to