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
All transactions between two independent unrelated entities take place at a certain price (unless it is a case of gift or sample). Transfer Price, means
Applicability of TP provision in case of transaction between the Enterprise and its Segment /Divisions Transfer Pricing provisions can be used for arriving at the
Business transaction, by a company, can spread over more than one country. For example, if a US company , which has a factory in New
CA Final Non Resident Taxation Case Studies on International Taxation by CA Arinjay Jain Sir for November 2020, which help to practice questions related to
CA Final Transfer Pricing Case Studies on International Taxation by CA Arinjay Jain Sir for November 2020, which help to practice questions related to CA
Scope of total income –The quantum of tax levied on any person, in a country, depends upon his residential status. The total taxable income of