Introduction “Arise, awake, and stop not till the goal is reached” said by Swami Vivekanada seems to be the motto of the Indian government which is relentlessly working on bringing India at Global footing as far as the taxation laws are concerned. Along with India many other nations have joined … [Read more...]
Transfer Pricing Methods
Due to increasing cross border transactions, Transfer pricing has become an important international tax issue affecting the MNCs. One of the most essential and contentious facets of transfer pricing provisions is to derive an accurate ALP. Section 92 of Income Tax Act lays down that any income … [Read more...]
Secondary Adjustment in case of Transfer Pricing
Introduction The concept of Secondary Adjustments is introduced in the arena of Transfer Pricing laws by Finance bill 2017 (hereinafter referred as the Bill). A new section 92CE is inserted in the Income Tax Act,1961(hereinafter referred as the Act), giving statutory validity to this concept. The … [Read more...]
Deemed international Transaction under Transfer Pricing
Introduction With the world turning into one global entity, trade and commerce has increased leaps and bounds. Along with the benefits it carries, there are many complex issues which need to be addressed. One of these issues is tax evasion and base erosion. Transnational Enterprises arrange their … [Read more...]
Multilateral Instrument (MLI) Convention
INTRODUCTION MLI Convention aims to implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. On 7th June, 2017, 70 Ministers and other high level representatives participated in the signing ceremony of MLI. This Convention is a product of Organisation for Economic … [Read more...]
Low Value-Adding Intra-Group Services – A welcome introduction
The Safe Harbour Rules (SHR) were amended by Notification No. 46/2017 dated 07-06-2017 issued by the Ministry of Finance, Central Board of Direct Taxes (CBDT). The term Safe Harbour is defined under section 92CB of the Income Tax Act, 1961 as circumstances under which the authorities shall accept … [Read more...]
Amendment in Safe Harbour Rules – A step towards sanity
Introduction Due to the increasing complexity of transaction between enterprises of the same group and manipulation of prices by them in order to avoid the burden of taxation in relation to international transactions, the Transfer pricing regulations by the Finance Act 2001 were … [Read more...]
Pradhan Mantri Garib Kalyan Deposit Scheme (PMGKDS) 2016 FAQ
1. What is Pradhan Mantri Garib Kalyan Deposit Scheme (PMGKDS), 2016 Pradhan Mantri Garib Kalyan Deposit Scheme (PMGKDS), 2016 is a scheme notified by the Government of India on December 16, 2016 which is applicable to every declarant under the Taxation and Investment Regime for Pradhan Mantri … [Read more...]
Income Tax Department Identifies 67.54 lakh Potential Non-Filers for F.Y. 2014-15
The Non-filers Monitoring System (NMS) was rolled out for identification of non-filers with potential tax liabilities. Data analytics carried out by the Systems Directorate of Central Board of Direct Taxes (CBDT) identifies non-filers about whom specific information is available in the AIR, CIB and … [Read more...]
Reporting Cash Transactions under Rule 114E of Income tax
Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes New Delhi, 22nd December, 2016. Press Release Reporting Cash Transactions under Rule 114E of Income –tax Rules, 1962. Rule 114E of Income-tax Rules, 1962, for furnishing statement of … [Read more...]
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