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RECENT TRIBUNAL RULING (SULZER PUMPS) ON CONTRACT MANUFACTURING OPERATIONS
Recently, Mumbai Tribunal in Sulzer pumps India Pvt. Ltd. (2018) 54 CCH 543 MumTrib, had the occasion to distinguish between a ‘contract manufacturer’ and...
TAXATION, TRANSFER PRICING AND DIGITALIZATION
India stands as one of the fastest growing economies of the world today and is expected to sustain the growth rates in the next several years, as per reports of the World...
FUTURE OF LITIGATION - DRP, APA, MAP AND ARBITRATION
Direct tax collection in India in Financial Year (‘FY’) 2002-03 was INR 83,088 Crores (INR 830.88 billion). However, in FY 2016-17 the direct tax collection...
TRANSFER PRICING â?? ART, SCIENCE OR LAW
“Transfer pricing is not an exact science but a method of legitimate quantification which requires exercise of judgment on the part of the tax administration and the...
Digital technologies have allowed for innovation in business models such as market place e-commerce platforms, aggregators, social media platforms, entertainment streaming...
TAX LITIGATION FUTURE SCENARIO
India in recent years has embarked upon improving the fiscal environment, and in that respect ushered in GST rules in July 2017. Recent tax policy changes, particularly,...
CRYSTAL GAZING IN TRANSFER PRICING - GLOBAL PROSPECTIVE
In 2015, the OECD[1] released final reports on the 15 Action Plans (AP) of the BEPS[2] project which probably, is the most comprehensive work done in the field of...
AOP NOT AN 'ELIGIBLE ASSESSEE' UNDER DRP MECHANISM
In the appeal before DRP, assessee contested that the assessee is not an “eligible assessee” as defined under section 144C(15) of the Act and neither there was...
INDENTING OR TRADING - THE TRANSFER PRICING DEBATE
Background More than a decade since introduction of transfer pricing regulations, India has seen eleven round of transfer pricing assessment. With a wide variety of...
Bombay High Court: Issuance of Shares at Premium Per se does not yield â??Incomeâ??
Transfer pricing controversies have been viewed as an emblematic of the difficulty of doing business in India. This sentiment has been widely shared by CEO’s across...
Bombay High Court: Issuance of Shares at Premium Per se does not yield ‘Income’
Transfer pricing controversies have been viewed as an emblematic of the difficulty of doing business in India. This sentiment has been widely shared by CEO’s across...
HC ON LG KOREA'S INDIA PE - 31 UNCONSIDERED ASPECTS!
A recent ruling of the Allahabad High Court, dismissing a writ application filed by LG Electronics Korea (LG Korea) [TS-234-HC-2014(ALL)-TP], challenging notices of...
â??ACCRUAL OF INCOMEâ?? IMPERATIVE FOR APPLICATION OF TP REGULATIONS?
INTRODUCTION The subject of transfer pricing has always been dubbed as an art as well as science. Even though the transfer pricing regulations (TPR) form part of the Indian...
INDIA AND BEPS - LOCATION SAVINGS - A "DIS"ADVANTAGE?
The Organization for Economic Co-operation and Development (OECD) on September 16, 2014 issued its first seven deliverables under Action Plan to address Base Erosion and...
RELATED PARTY TRANSACTIONS - NOT JUST A TAXING ISSUE
The new Companies Act, 2013 (‘new Act’) which replaces the old Act of 1956, got the President’s assent on 29th August, 2013 and officially became...
Transfer Pricing aspects of Receivables from Associated Enterprises
Summary Transfer pricing aspects of extended credit period to AE is a vexed issue. Receivables emanate from sale or service transaction and they are concomitant of sale. ...
TO BE OR NOT TO BE â?? A â??PEâ??
The business model of a foreign company setting up its subsidiary in India to extend the back end support operations to its holding company has been quite an 'attention...
Domestic TP u/s 80-IA(8) - Whether transfers between tax holiday units covered?
Introduction: The Finance Act, 2012 widened the scope of transfer pricing by extending the transfer pricing provisions to specified domestic transactions...
INDIAN TP PERSPECTIVE ON OECD'S REVISED DRAFT ON INTANGIBLES
Background The issue of transfer pricing for intangible property (IP) has proven to be one of the most challenging topics in the transfer pricing area, both from a...
DIFFERENTIAL TOLERANCE RANGE - DOES IT MEET DOCTRINE OF REASONABLE CLASSIFICATION?
In April this year, the Central Board of Direct Taxes notified the revised tolerance band of 3 percent available to taxpayers in determination of arm’s length price....
