Category: CA Final International Tax Book

CBDT  has prescribed the ‘Other Method’ Transfer Pricing by inserting Rule 10AB to the Income-Tax Rules. For determination of arm’s length price in relation to

Under Transactional Net Margin Method (TNMM), a comparison is made for the operating profit derived by tested party,  from a controlled transaction, relative to an

Transfer Pricing provisions are applicable to determine the arm’s length price of ‘International transaction’ and ‘Specified domestic transactions” between Associated enterprises. Even though domestic transactions

DEEMED ASSOCIATED ENTERPRISES – SECTION 92A (2) READERS INFORMATION: – The general application of definition of AE , discussed in Section 92A(1) may not be

Associated Enterprises Transfer Pricing – SECTION 92A (1) Transfer Pricing provisions are applicable for international transaction between Associated enterprise (It is also applicable on certain

COMPUTATION OF INCOME HAVING REGARD TO THE ALP – SECTION 92 – APPLICABILITY OF ARM’S LENGTH PRINCIPLE Section 92 of the IT Act,  provides the

Evolution of Transfer Pricing in India [Pre 2001 ERA] – Section 92 The Transfer Pricing rules and regulations in India can be broadly covered under

What is Transfer Pricing? Different countries have different rules on taxation, in terms of tax rates, tax exemptions etc. For example, in the above Case,

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