OBJECTIVE OF INTRODUCTION OF SECTION 94A OF INCOME TAX ACT The main objective of Section 94A of the Income Tax Act, 1961 is to discourage assessees from entering into transactions with persons located in countries or territories which do not exchange tax information with India. NOTIFIED JURISDICTIONAL AREA – SECTION 94A The Central Government may … Read more
Transfer Pricing Course Online (Updated 2019) – by CA Arinjay Jain Type Recorded Lectures Course Duration: 11.5 Hrs Language Hinglish Transfer Pricing Online Course – Curriculum Basics of Transfer Pricing online Course What is Transfer pricing – Meaning of Transfer Pricing and Objectives of Transfer Pricing Transfer Pricing Concept under International Taxation Transfer Pricing – … Read more
Transfer Pricing MCQ with Answers, cover MCQ on various topics like Concept of Associated Enterprises (Including Deemed Associated Enterprises, Computation of Arm’s Length Price, Methods to compute Arm’s Length price, penalties for non compliance with ALP. The topic of Transfer Pricing International Tax MCQ is a part of our International Taxation Course, which is offered … Read more
Miscellaneous Transfer Pricing Provisions 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 with India. NOTIFIED JURISDICTIONAL AREA – SECTION 94A The Central Government may notify any country or territory outside India as a Notified Jurisdictional Area (NJA), if … Read more
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, read with section 295, inserted Rules 10TH, 10THA, 10THB, 10THC, & 10THD and has prescribed the safe harbour rules for specified domestic transaction as well. ELIGIBLE ASSESSEE WHO CAN OPT … Read more
Safe Harbour Rules for International Transactions Transfer Pricing involves lot of dispute amongst taxpayers and tax authorities, on how much should be the margins of various transactions/ what should be the ALP of given transactions between AE’s. Given the ever changing technologies and mode of operating business, the margins, ALP determined once may not be … Read more
Secondary Adjustment – Section 92CE of Income Tax Act The Finance Act, 2017 has inserted the provision of “Secondary adjustment” to reflect that the actual allocation of profits between the assessee and its AE are consistence with the transfer price determined as a result of primary adjustment, thereby removing imbalance between cash account and actual … Read more
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 determine the arm’s length price in relation to international transaction and specified domestic transaction under the following circumstances : – a. The price charged or paid in an international transaction … Read more
The tax dispute resolution mechanism under transfer pricing in India consists of the following forums : – DRP or Appeal before the Commissioner of Income Tax (Appeals); Income Tax Appellate Tribunal; The High Court / Supreme Court; Safe Harbour Rules; Advance Pricing Agreement; and Mutual Agreement Procedure DISPUTE RESOLUTION PANEL – [SECTION 144C] – FEATURES … Read more
For under reporting of income – Section 270A Section 270A provides for levy of penalty @ 50% of tax payable (including surcharge and education cess), for under-reporting of income. However, additions made in conformity with ALP, determined by TPO would not be considered underreported income if : – Assessee has maintained information and documents, as … Read more