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DTAA - Receipts from transportation of cargo through feeder vessels obtained under slot hire arrangements are covered by Article 8 of the India-Germany DTAA; not taxable in India u/s 44B: ITAT (See Breaking News) TP - AMP expenses incurred by brand owner for its own business are revenue expenditures: ITAT (See Breaking News) TP - Statutory timelines prescribed u/s 144C(13) are mandatory, sacrosanct & fundamental to procedural discipline in tax administration - omission to pass final order within prescribed time frame invalidates such order: ITAT (See Breaking News) TP - Extending corporate guarantees falls within definition of international transactions u/s 92B as indirect long-term financing: ITAT (See Breaking News) I-T - Underwriting commissions do not constitute FTS because they represent fee for incurring financial risk rather than transmission of technical knowledge: ITAT (See Breaking News) I-T - Reimbursements did not attract TDS u/s 195: ITAT (See Breaking News) TP - Revenue's attempt to treat draft order as final assessment order u/s 143(3) by alleging ‘human error' is unsustainable: HC (See Breaking News) I-T - Situs of manufacturing activity in India suggests that income component is located in India, even if receipts emanate from abroad: ITAT (See Breaking News) INTL - In absence of international transaction, statutory obligations to maintain documentation u/s 92D & Rule 10D does not arise, thereby rendering levy of penalty u/s 271G unsustainable: ITAT (See Breaking News) I-T - Technical services are only taxable under ‘make available' if recipient absorbs skill to apply it independently: ITAT (See Breaking News) TP - ALP for international loans in foreign currency must be benchmarked against LIBOR applicable in borrower's country: ITAT (See Breaking News) TP - Economic adjustments for non-creditable customs duties and working capital cycles are mandatory to ensure comparability: ITAT (See Breaking News) TP - Parity must be maintained between operating cost and income base, specifically regarding ESOP reimbursements & foreign currency receivables: ITAT (See Breaking News) TP - TNMM is preferred over CUP method if there are significant contractual and economic differences between AE & non-AE transactions that cannot be accurately adjusted: ITAT (See Breaking News) I-T - Section 44C is an exhaustive provision for head office expenses meeting a specific tripartite test - YES: ITAT (See Breaking News) I-T - Foreign taxes paid, such as Japanese Inhabitant or Enterprise taxes, that do not qualify for credit u/s 90/91, are allowable as business expenditure u/s 37(1) r/w Explanation 1 to Sec 40(a)(ii): ITAT (See Breaking News) TP - If entity is debt-free, it cannot be presumed that borrowed funds were utilized to provide credit facilities to AEs : ITAT (See Breaking News) TP - Profit margin agreed upon in Bilateral APA for specific AEs constitutes reliable benchmark for determining ALP of similar transactions with non-covered AEs: ITAT (See Breaking News) TP - Once closely linked transactions are validly benchmarked under TNMM, segregating one component such as intra-group services for separate benchmarking can lead to impermissible double adjustment: ITAT (See Breaking News) TP - In back-to-back project execution model, CUP is appropriate method for benchmarking, and TNMM cannot be forced merely by treating Indian project office as captive sub-contractor: ITAT (See Breaking News)
 
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CBDT entered into 62 APAs in last fiscal
By TII News Service
Apr 01, 2022 , New Delhi

    

THE Central Board of Direct Taxes (CBDT) has entered into 62 Advance Pricing Agreements (APA) in FY 2021-22 with Indian taxpayers. This includes 13 Bilateral APAs (consequent to Mutual Agreement between India and its treaty partners) and 49 Unilateral APAs. With this, the total number of APAs since inception of the APA program has gone up to 421.

Despite severe economic and social disruption caused by the CoVID-19 pandemic in first part of the financial year, the number of APAs signed compares very well with the APAs signed in the preceding two years (31 APAs in FY 2020-21 and 57 APAs in FY 2019-20).

The APA Scheme endeavours to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and determining the arm's length price of international transactions in advance for the maximum of five future years. Further, the taxpayer has the option to rollback the APA for four preceding years, as a result of which, total nine years of tax certainty is provided.

The progress of the APA scheme strengthens the Government's resolve of fostering a non-adversarial tax regime and increasing the ease of doing business in India. CBDT appreciates the cooperative and transparent attitude of taxpayers in this regard.

 
 
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