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TP - In absence of segmental information regarding contract research & manufacturing activities, it is difficult to analyse main revenue and profit margin from contract research work: ITAT (See Breaking News) INTL - Addition framed u/s 56(2)(x) unsustainable, where difference between actual consideration & DVO-assessed value is only 4% & where ITAT benches have consistently applied the benefit of tolerance band to AY 2018–19: ITAT (See Breaking News) TP - Adjustment must be benchmarked using domestic Prime Lending Rate (PLR) & not LIBOR, where the Compulsorily Convertible Debentures are INR-denominated: ITAT (See Breaking News) TP - Transfer pricing additions not sustainable in light of bilateral & unilateral Advance Pricing Agreements entered between Assessee & CBDT: ITAT (See Breaking News) TP - TPO cannot reject TP study of assessee on ground that assessee has not availed all services agreed with AE: ITAT (See Breaking News) I-T - Genuine secondment arrangements with employer-employee relationship with, Indian entity are not subject to withholding tax: HC (See Breaking News) TP - Tolerance limit of 3% is applicable on transactions with AEs if assessee is not wholesale automobile trader: HC (See Breaking News) DTAA - Loss incurred by non-resident taxpayer from sale of non-grandfathered shares cannot be set off against capital gain, which is exempt from taxation in India: ITAT (See Breaking News) G20 GDP spikes by 0.9% in Q2 (See Brief ) DTAA - In selling of shares, possibility of rigging share prices leading to heavy capital gain and siphoning out gains to tax heavens, cannot be ruled out: ITAT (See Breaking News) TP - Functionally different companies cannot be considered as comparables: ITAT (See Breaking News) TP - If assessee has charged fees @0.5% on account of corporate guarantee provided by it, then such fee would be considered at ALP: ITAT (See Breaking News) TP - In case of default, there is always inherent risk in providing guarantees which may be reason that Finance provider insist on non-charging any commission from AE as commercial principle: ITAT (See Breaking News) TP - Corporate guarantee is not comparable to bank guarantee; commission charged cannot be evaluated based on bank guarantee rates: HC (See Breaking News) I-T - Expenses incurred by assessee in respect of Hyderabad unitis incurred for business purposes qualify to be considered u/s 37(1), if expenses are intrinsically connected with business of assessee: ITAT (See Breaking News) I-T - Export commission paid to non-residents for services rendered abroad without carrying out any business operations in India, is not taxable in India: HC (See Breaking News) TP - Adjustment made by TPO shall be restricted to international transactions alone, and not upon entire turnover/operating costs: HC (See Breaking News) I-T - Broadcasting license fees received for telecast of live matches cannot be considered as royalty: ITAT (See Breaking News) TP - TPO shall compute eligible profits as per Sec 80IA(8) with reference to rates at which respective State Electricity Boards/distribution companies has supplied electricity to end consumers in open market: 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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