Friday , September 22, 2017 |   06:10:43 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Instant Updates Newsletters
 
NEWS FLASH
 
I-T - Time limit imposed by provisions of Sec 153(2A) would come into force even if part order is remanded to AO: HC (See 'Breaking News') Taxation of Indirect transfer- India was right after all (See 'TII EDIT') TP - TNMM is most appropriate method for benchmarking international transactions which did not involve transfer of unique intangibles: ITAT (See 'Breaking New's) TP - Huge profit / turnover is no ground for exclusion of comparable, unless such difference materially affects cost: ITAT (See 'Breaking News') DTAA - Salary paid to expatriates working in India exclusively for PE of foreign entity in India, will not be covered by Section 44C: ITAT (See 'BreakingNews) I-T - Assessee's books should not be rejected, if it has fulfilled all requirements of Section 44BBB(2) and also had past experience to estimate total cost of turnkey projects: HC (See 'Breaking News') GST - Ground-level problems crying for solutions! (See 'THE COB(WEB)' in TIOL) TP - TPO cannot determine value of management services rendered by AEs to Rs Nil, without applying any transfer pricing methods: ITAT (See 'Breaking News') TP - No addition to ALP can be made, where weighted average margin of comparables is within 5% of margin shown by assessee: ITAT (See 'Breaking News') I-T - When no income has accrued or deemed to be accrued in India to foreign entity, no inference can be drawn that such entity has business connection in India: ITAT (See 'Breaking News') DTAA - Consideration received by non-resident entity from sale of 'standard software', would amount to 'business income' and not royalty: HC (See 'Breaking News') I-T - Profits relating to services rendered by foreign entity, no matter rendered within India or outside India in respect of Indian projects, are taxable in India: ITAT (See 'Breaking News') DTAA - Disallowance of 50% of management charges paid by UK entity is not justified when term 'managerial' is missing in definition of FTS under India-UK DTAA: ITAT (See 'Breaking News') TP - Companies accepted by both Assessee & Revenue as functionally comparable, should first be included in list of comparables: ITAT (See 'Breaking News') TP - In absence of change in circumstantial facts, Assessee's computation of ALP with regard to purchase of capital assets, deserves to be accepted in subsequent A.Ys: ITAT (See 'Breaking News') DTAA - Offshore revenue from supply of non-transferable software, is not taxable as 'royalty', either under I-T Act or DTAA provisions: ITAT (See 'Breaking News') I-T - Contract of sale taking place offshore, cannot be taxed in India: HC (See Breaking News') Auto exchange of tax information - 49 jurisdictions to activate services this month (See 'TII Brief') I-T - When assessee is a mere distributor with no proprietory rights of products, payments remitted to non-resident company cannot be treated as royalty: ITAT (See 'Breaking News') I-T - Non mentioning of specific issues of Assessee in its order, shows failure of ITAT to address them, if they were raised in memo of appeals: HC (See 'Breaking News') I-T - Interest expenses incurred in relation to ECBs, availed for acquiring fixed assets for continuation of existing business, deserve to be allowed: ITAT (See 'Breaking News')
 
TII SEARCH
 
 
   
Home >> News Brief
 

CBDT enters into four more APAs
By TII News Service
Feb 07, 2017 , New Delhi

    
THE Central Board of Direct Taxes (CBDT) has entered into four more unilateral Advance Pricing Agreements (APAs) on February 6, 2017.

The four APAs signed pertain to the Manufacturing, Financial and Information Technology sectors of the economy. The international transactions covered in these agreements include Contract Manufacturing, IT Enabled Services and Software Development Services.

With this, the total number of APAs entered into by the CBDT has reached 130. This includes 8 bilateral APAs and 122 Unilateral APAs. In the current financial year, a total of 66 APAs (5 bilateral APAs and 61 unilateral APAs) have already been entered into. The CBDT expects more APAs to be concluded and signed before the end of the current fiscal.

The APA Scheme was introduced in the Income-tax Act in 2012 and the “Rollback” provisions were introduced in 2014. The scheme endeavours to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and determining the prices of international transactions in advance. Since its inception, the APA scheme has evinced a lot of interest from taxpayers and that has resulted in more than 700 applications (both unilateral and bilateral) being filed so far in about five years.

The progress of the APA Scheme strengthens the Government's resolve of fostering a non-adversarial tax regime. The Indian APA program has been appreciated nationally and internationally for being able to address complex transfer pricing issues in a fair and transparent manner.

 
 
gmail login
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAAs
  • TIEAs
  • Circulars (I-T Act, 1922)
  • Circulars
  • Instructions
  • DRP Panel
  • Administrative Orders
  • Notifications
  • I-T Act, 1961
  • Relevant Portion of I-T Rules,1962
  • Relevant Portion of I-T Act,1922
  • GAAR
  • Equalisation Levy
  • Draft Guidelines
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • DTC Bill
  • UN Model
  • Miscellaneous
  • Guidance Notes - AEOI
  • OECD Conventions
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • Circulars
  • Instructions
  • Notifications
  • Relevant Sections of Act
  • TP Rules
  • Forms
  • Miscellaneous
  • APA Annual Report
  • APA Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • RBI Circulars
  • FDI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • Black Money Act
  • 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 on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • CBR Act, 1963
  • MCA Circular
  • Book Review
  • Limitation Act
  • SSAs
  • EPFO
  • FAQs
  • Acts
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifcations
  • Types of Visa
  • Agreements
  • Arbitration
  • Model Text
  • Relevant Portion of I-T Act
  • Circulars
  • I-T Rules, 1962
  • MISC
  • Notifications
  • Subscribe
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2016 Taxindiainternational.com Pvt.Ltd. All rights reserved. | Powered by 4th Dimension