1. In the given case, the assessee is engaged in manufacturing of chemicals. It had sold said products to its AE and non-AE and applied TNMM to benchmark said transactions.2. However, Ld. TPO relying upon internal CUP and made addition to the assessee’s ALP in respect of various products sold to AE.3. Since intra AE transactions were fundamentally different in…
Author: Reetika Agarwal
Tax Updates-July, ’20
Sharing with you “Tax Updates and Compilation of Judicial Rulings of Supreme Court, High Court, Income Tax Appellate Tribunal including rulings in the area of International Taxation and Transfer Pricing_July ’20”. Hope you may find it useful and informative too. Please visit the below link for detail: #taxation #internationaltax #transferpricing
UN Committee approved Transfer Pricing Manual Updates
Approved documents include: 1. Revised Chapter B.2 on comparability: Revisions were designed to provide consistency between UN TP Manual and the Platform for Collaboration on Tax’s comparability toolkit. 2. Revised Chapter B.5: On group synergies, which includes additional guidance on centralized procurement functions. 3. Approved Chapter B.9.4: On financial transactions dealing with guarantees. 4. Revised Chapter C.1: Which merges the…
BENEFIT OF SECTION 10A OF THE ACT IS ALLOWED ON THE ENHANCED INCOME PURSUANT TO THE MUTUAL AGREEMENT PROCEDURE (MAP) RESOLUTION
Case Name: Dell International Services India Private Limited v. Dy. CIT [IT/(TP)A No. 879/Bang/2018] [AY 2007-08] Outcome: In favor of Assessee Facts: ITeS Segment: SWD Segment: Issues: ITAT’s Decision: ITeS Segment: Observations and findings of Hon’ble ITAT are: “55.12 The first proviso to section 92C(4) recognizes the commercial reality that even when a transfer pricing adjustment is made under that…
CBDT Notification- Further extending few of the time limits of compliances under Taxation & Other Laws
The salient features of which are as under: