Taxindiainternational.com - International Taxation, Transfer Pricing, DTAA, NRI, FDI, Income Tax, Custom, Service Tax, Caselaws, Notifications, Circulars, Analysis

INTL TAXATION TP CUSTOMS FDI MISC VISA BIPA NRI

Newsletter Archive

NEWS FLASH

TP - Whether benefit of +/-5% tolerance band can be availed, when difference between net profit margin declared by assessee and ALP determined by TPO based on TNMM method, is less than 5%. (See 'TII Breaking News')

Whether when difference between profit margin of single comparable taken in TP study and profit margin of assessee, remunerated on a cost plus basis, was less than 5%, Revenue is justified to disallow this benefit, under proviso to sec 92C(2) on ground that comparable price was only one (See 'TII Breaking News')

Emerging economies performing below potential; Global recovery delayed: UN Report... (See 'TII Brief')

Union Cabinet okays CBDT's Cadre-restructuring plan; sanctions 1349 more IRS posts + 19402 non-IRS posts at addl cost of Rs 449.7 Cr annually

TP - Whether when DRP had confirmed transfer pricing adjustment against assessee, in a cursory manner without ascribing cogent reasons, order was liable to be set aside as non-speaking order (See 'TII Breaking News')

TP - Whether benefits arising out of cost sharing arrangement between Parent and its Indian subsidiary towards sponsorship of Cricket World Cup event can be apportioned, on basis of global sales of entire group, although benefit accrued only to those entities of group having presence in cricket playing nations - Whether parent company is liable to contribute towards advertisement expenditure of its Indian subsidiary, for having availed direct or indirect benefits out of such publicity, although such contributions are never made in arm's length circumstances - Whether while considering cost contribution, it is necessary to bear in mind penetration level of sales in market of advanced countries (See 'TII Breaking News')

Vodafone Tax Bill: A Good Case for Settlement by Agreement! (See 'The Cob(Web) Column)

Africa is growth continent for 21st Century: WTO Chief (See 'TII Brief')

I-T - Whether under AS-7 percentage of completion method is one of the methods for recognizing revenue on construction contracts - Whether it can be held that AS-7 is against the provisions of law or the profits cannot be determined for the purpose of taxability (See 'TII Breaking News')

TP - Whether companies with multiple times higher turnover than that of the assessee could be included as comparables for making a TP adjustment - Whether for applying arithmetical mean, PLI for adjustment amounts received as reimbursement should be taken into account. (See 'TII Breaking News')

OECD okays revision of safe harbours provisions in TP Guidelines... (See 'TII Brief')

India-USA DTAA - Whether when employees of foreign company frequently visited premises of Indian subsidiary to provide supervision, direction and control over operations of such subsidiary, it can be said that foreign company had a fixed place of business at its disposal (See 'TII Breaking News')

India-Japan DTAA - Whether the offshore services rendered in connection with turnkey project fall within purview of section 9(1)(vii), even if entire services were rendered outside India but utilized in India (See 'TII Breaking News')

French Senators voice against levy of Behavioral Tax on wine ... (See 'TII Brief')

EU, Switzerland sign Competition Cooperation pact... (See 'TII Brief')

45 Tax Administrators resolve to track transnational tax fraud (See 'TII Brief')

India-UK DTAA - Whether when there is no co-relation between actual expenditure incurred by HO and that recovered from branches and when there is a profit element in recovery from branches it can be accepted that HO merely recovered costs incurred from Indian branch - Whether an auditor's certificate mentions that head office expenses have only been initialed by them on basis of statements furnished by assessee, it can be said to form a basis of allocation of such expenses to branch(See 'TII Breaking News')

Whether TP adjustments can be made in respect of AMP expenses - Whether when assessee received subsidy from parent in form of advertising support, and had shown same relating to trade discount and volume rebates can be treated as part of aggregated AMP expenses while benchmarking this international transaction against comparables (See 'TII Breaking News')

CBDT stitches FAQs on APA (See 'TP' for details)

India-France DTAA - Whether when DTAA does not say anything about inclusion of surcharge and education cess for purpose of deduction of tax at source, there is an apparent conflict between Income-tax Act and DTAA with regard to deduction of tax at source - Whether if provisions of DTAA are more beneficial to taxpayer, then provisions of DTAA would prevail over Indian Income-tax Act -Whether when DTAA is silent about surcharge and education cess for purpose of deduction of tax at source, taxpayer may take advantage of provision in DTAA for deduction of tax (See 'TII Breaking News')

TII SEARCH

Home >> FDI>> FDI Circulars

Member Login


Username	:
Password	:

		Subscribe Forgot Password

INTL TAXATION	TP	CUSTOMS	FDI	MISC	VISA	BIPA	NRI	TII
DTAAs TIEAs Circulars (I-T Act, 1922) Circulars Instructions Notifications DRP Panel Administrative Orders Committee Reports I-T Act, 1961 Relevant Portion of I-T Rules,1962 Relevant Portion of I-T Act,1922 Finance Acts Manual on EoI DTC Bill AAR Cause List UN Model Taxation Misc GAAR	Circulars Instructions Notifications Relevant Sections of Act TP Rules Forms Miscellaneous APA Rules APA FAQ	Circulars Valuation Rules Customs Act, 1962 Customs Tariff Act, 1975 Customs Manual Exchange Rate Notifications SEZ Circulars	FEMA Act Exchange Manual Fema Notifications Master Circulars Press Notes Rules RBI Circulars FDI Circulars Reports FDI Approved RBI Other Notifications	PMLA Notification PMLA Instruction PMLA Bill FM Budget Speeches SEBI Multimodal Transportation Vienna Convention NBFC Reports EXIM Bank LoC Manufacturing Policy FTDR Act, 1992 Intellectual Property White Paper Posting Policy Black Money Fact-Sheet	SSAs EPFO FAQs Acts Rules Guidelines Tourist Visa Notifcations	BIPA	Circulars Relevant Portion of I-T Act I-T Rules, 1962 Notifications	Subscribe About Us Contact Us


A Taxindiaonline Website. Copyright © 2013 Taxindiainternational.com Pvt.Ltd. All rights reserved. \| Powered by 4th Dimension