TRANSFER PRICING DISPUTE ON â??MARKETING INTANGIBLESâ?? IN THE POST BEPS SCENARIO

Introduction India has emerged as the leading jurisdiction in terms of transfer pricing litigation and jurisprudence. The Indian transfer pricing landscape thus far is...

TRANSFER PRICING ASPECTS OF BUSINESS RESTRUCTURING

Introduction Transfer pricing is an art and not an exact science. Indian TP regulations and also international practices in the transfer pricing arena are fast evolving....

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...

TRANSFER PRICING PROVISIONS NOT TO APPLY ON TRANSACTIONS WITH PE OF FOREIGN PARENT IJM (India) Infrastructure Ltd. vs. Assistant Commissioner of Income-tax, Circle - 2(1), Hyderabad

Synopsis 1. Summary of the decision 2. Comments Summary of the decision The assessee IJM (India) Infrastructure Ltd. (“IJM”), was an...

TRANSFER PRICING AND LOCATION SAVINGS The LINKS AND DE-LINKS

SYNOPSIS 1. Introduction 2. Indian Outlook 3. Conclusion Introduction: Location savings are generally termed to be meant as cost...

TRANSFER PRICING- SPECIFIED DOMESTIC TRANSACTION

SYNOPSIS 1.Background 2. Applicability of transfer pricing provisions to Specified Domestic Transactions 3.Meaning of arm’s length price 4....