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TP - Such companies having turnover ten times higher than that of assessee, can be adopted as comparables: ITAT (See 'Breaking News') TP - It is it case for remand for computing ALP of international transactions after applying Most Appropriate Method, considering that the assessee selected its AEs as tested parties, in contravention of settled principle that AE cannot be adopted as tested party : ITAT (See 'Breaking News') Finance Act 2020 (See 'Intl Misc') RBI goes for 75 basis point cut in repo rate & 100 basis point cut in CRR + permits all lending institutions to grant 3 months moratorium on EMIs for all loans + no impact on assets classification RBI liquidity injection goes up to 3.2% of GDP TP - Where transactions fall under Section 92BA(1) which stands repealed, imposition of penalty for failure to furnish report in Form 3CEB in terms of Section 92E, is not sustainable: ITAT (See 'Breaking News') TP - Where international transactions forming part of manufacturing activity segment is closely linked with distribution & after sales activity, they need to be benchmarked independent of each other & not together: ITAT (See 'Breaking News') COVID-19 Fall-out - Is PM losing time to 'Flatten The Curve' of mounting economic miseries! (See 'The Cob(Web)') I-T - Where technical services provided by swedish company for maintenance of existing GSS software to its Indian AE does not result in provision of any technical knowledge, amount received for such services is not taxable u/s 9(1)(vi) & (vii) or under Article 12(3) of India -Sweden DTAA as FTS - YES: ITAT (See 'Breking News') I-T - Payments made by Indian patent attorney to his foreign associates in respect of consultancy services is taxable in terms of FTS u/s 9(1)(vii) r/w/s 195: ITAT (See 'Breaking News') Finance Bill 2020 as passed by Lok Sabha (See 'Finance Act' in Intl Misc) TP - TPO is vested with power u/s 92CA to determine ALP of specified domestic transactions without collecting data available in public domain or collecting data from private domain by issuing notice u/s 133(6): ITAT (See 'Breaking News') I-T - Salary received by Indian resident for services rendered in Australia, are taxable in India, considering that such income is duly offered to tax in Australia: ITAT (See 'Breaking News') Income tax return filing for FY 2018-19 - FM announces extension of due date to June 30 & reduction in interest rate from 12% to 9% and also reduction in interest rate for delayed deposit of TDS from 18% to 9% FM announces extension of due date for linking Aadhaar & PAN to June 30 + Vivad Se Vishwas scheme to be valid till June 30 and waiver of 10% additional tax till June 30 granted + Due date extended till June 30 for all statutory compliance, approval order, notice, report & appeal etc under various laws such as Benami Act, Black Money Act, STT, CTT and Wealth Tax Act I-T - Payment received for IT support service rendered by assessee, can be treated as Fees for Technical Service, where no information concerning technical, industrial or commercial knowledge, is being imparted: ITAT (See 'Breaking News') TP - It is fit case for remand where TPO does not record reasons for rejecting CUP method for benchmarking international transactions, as favored by assessee: ITAT (See 'Breaking News')
 
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CbC reports - Govt notifies relevant authority
By TII News Service
Mar 19, 2020 , New Delhi

    
SO as to ensure that a multinational enterprise would report its profit correctly where it is earned, the Organisation for Economic Cooperation and Development (OECD) had developed an Action Plan called “Base Erosion and Profit Shifting (BEPS) Action Plan 13”. Under BEPS Action Plan 13, all large multinational enterprises (MNEs) are required to prepare a country-by-country (CbC) report with aggregate data on the global allocation of income, profit, taxes paid and economic activity among tax jurisdictions in which they operate. In essence, CbC Report is an annual return that breaks down key elements of the financial statements by jurisdiction. A CbC report provides local tax authorities visibility to revenue, income, tax paid and accrued, employment, capital, retained earnings, tangible assets and activities of the concerned MNE.

This CbC report is used as a corroborating material by Income tax Authorities in carrying out revenue risk assessment.

As per corresponding provisions of Indian Income tax Laws, every MNE group which has a constituent entity resident in India is mandated to notify the Income-tax Department its parent entity and alternate reporting entity and the countries where such entities are resident. Such parent entity or alternate reporting entity is required to furnish a report called “Country-by-Country Report” specifying certain information including:

the aggregate information in respect of the amount of revenue, profit or loss before income-tax, amount of income-tax paid, amount of income-tax accrued, stated capital, accumulated earnings, number of employees and tangible assets not being cash or cash equivalents, with regard to each country or territory in which the group operates;

the details of each constituent entity of the group including the country or territory in which such constituent entity is incorporated or organised or established and the country or territory where it is resident;

the nature and details of the main business activity or activities of each constituent entity.

For the above stated purpose, the Central Board of Direct Taxes(CBDT) had notified Rules 10DA, 10DB and Form Nos. 3CEAA to 3CEAE in Income-tax Rules, 1962.

The Income Tax (2 nd Amendment) Rules, 2020 has amended rules 10DA and 10DB and notification no. 03/2020 dated 06.01.2020 has already been issued in this regard. As per the amended sub-rule(1) of rule 10DB, the income tax authority for the purpose of section 286 shall be the Joint Commissioner as may be designated by the Director General of Income tax (Risk Assessment).

In view of the above amendment and in exercise of the powers conferred by section 286 of the Act, the Director General of Income tax (Risk Assessment) has designated the Joint Director of Income tax (Risk Assessment)-1 having office at 4th Floor, C-Block, Dr. S.P. Mukherjee Civic Centre, Minto Road, New Delhi-110002 as the Income tax Authority for the purpose of section 286 of the Act, with effect from the first day of April, 2020.

 

 
 
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