Thursday , November 21, 2024 |   14:20:59 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
TP - High cost for services rendered for implementing a software does raise doubts, but mere suspicion is no basis for holding that no services were rendered by AE for said purpose: ITAT (See 'Breaking News') TP - Companies which are distinct from assessee on account of high turnover, functional dis-similarity & difference in working capital merit being excluded as comparables for benchmarking purposes: ITAT (See 'Breaking News') INTL -Income of a non-resident assessee cannot be taxed in India where such person is employed abroad during relevant period: ITAT (See 'Breaking News') DTAA - Fee received for providing technical non-invasive inspection & integrity assessment services for offshore pipelines, cannot be taxed as Fees for Technical Services, considering that Make Available requirement is not satisfied in this case: ITAT (See 'Breaking News') I-T - Receipts from supply of software products cannot be taxed as royalty or FIS, in absence of transfer of any technical know-how with those products: ITAT (See 'Breaking News') I-T - It is wholly inequitable for Department to give short credit to tax duly deducted and deposited based on claim that may be made in return of income: HC (See 'Breaking News') I-T - Bandwidth charges remitted to telecom service providers cannot be treated as royalty either under treaty provisions or u/s 9(1)(vi) of Income tax Act, and hence does not attract TDS: ITAT (See 'Breaking News') DTAA - Notion that enduring benefit gained by client through repairs & maintenance is akin to make available, is incorrect: ITAT (See 'Breaking News') DTAA - Providing customer-based information & guidance does not entail problem solving skills or operations or knowledge which allows recipient to perform services independently in future; consideration therefor not treatable as FTS: ITAT (See 'Breaking News') INTL - Revisionary order passed u/s 263 is invalid, where assessee is not given opportunity to contest the allegations levelled by the CIT: HC (See 'Breaking News') INTL - Buyback transactions would not be treated as transfer for capital gains purposes; power of revision is unwarrantedly exercised where it is based on a hypothetical assumption of facts: ITAT (See 'Breaking News') TP - Resale Price Method for benchamarking purposes is appropriate for assessee-company whose activities are limited to purchasing & reselling products without adding any value & which is consistent with those of a routine distributor: HC (See 'Breaking News') I-T - Payments made overseas for general support services, for which no technology was made available, cannot be taxed as 'FTS': ITAT (See 'Breaking News') I-T - If purported reasons that prompted AO to reassess and disallow DAP expenditure incurred on production, only demonstrate change of opinion on part of AO, then same can't form basis of reopening: HC (See 'Breaking News') INTL - Re-assessment proceedings invalidated where based on erroneous information & where commenced in a mechanical manner & without due application of mind: ITAT (See 'Breaking News') TP - AO could not have assumed jurisdiction u/s 147 based on audit objections after expiry of four years from relevant A.Y: HC (See 'Breaking News') INTL - Additions framed u/s 69 are invalid where assessee substantiates nature & source of investment & thus discharges onus of proof: ITAT (See 'Breaking News') DTAA - Comparable company merits being excluded where it operates with extraordinary margins & diverse business interests, including intangibles in contrast to assessee-company: ITAT (See 'Breaking News') TP - As is trite law, transfer pricing adjustment has to be done only in respect of international transactions with associated enterprises & not at entity level: ITAT (See 'Breaking News') DTAA - Payments made by Google India Pvt Ltd. to Google Ireland Limited (GIL) for the Adwords program are not in the nature of royalty or FTS & therefore, cannot be taxed in the hands of assessee: ITAT (See 'Breaking News') TP - No separate ALP adjustment is required for payment of royalty if TNMM approach has been adopted at entity level: ITAT (See 'Breaking News')
 
TII SEARCH
 
 
   
Home >>
 

CBDT invited applications for Under Secretaries in APA section
By TII News Service
Nov 14, 2018 , New Delhi

    

GOVERNMENT OF INDIA
MINISTRY OF FINANCE
DEPARTMENT OF REVENUE
CENTRAL BOARD OF DIRECT TAXES
FOREIGN TAX AND TAX RESEARCH DIVISION -I
NEW DELHI

Dated: November 14, 2018

All Principal Chief Commissioners of Income Tax (CCA)

Subject: Calling for applications for filing up the posts of Under Secretaries in the APA Sections of FT & TR-I Division of the CBDT

Two posts of Under Secretaries in the APA Sections of FT & TR-I Division are likely to fall vacant shortly. APA or Advance Pricing Agreement Programme of the CBDT endevours to grant certainty around transfer pricing matters to taxpayers in India. As Under Secretaries manning the APA Sections, the officers will assist the Indian Competent Authority (Joint Secretary, FT & TR-I, CBDT) in the Mutual Agreement Procedure (MAP) on transfer pricing issues under India's bilateral tax treaties with other countries. Further, the officers will also assist the Board in entering into unilateral and bilateral Advance Pricing Agreements with taxpayers.

2. In this regard, applications from willing IRS officers belonging to the 2012, 2013 and 2014 batches are invited. IRS officers who have worked/are currently working in the areas of International Taxation, Transfer Pricing or Advance Pricing Agreements may be given preference. Applications may be forwarded to Joint Secretary, FR & TR-I, CBDT, Room No. 803, Hudco Vishala Building, Bhikaji Cama Place, New Delhi - 110066 latest by 30th November 2018. Applicants may also send advance copies of their applications together with a brief resume to sobhan.kar@nic.in.

[File No. 500/12/2018-APA-II]

Sobhan Kar
Director (APA)

Proforma

Application for the posts of Under Secretaries in the APA Sections of FT & TR-I CBDT

Item
Details
Name of the officer
 
Civil List Code
 
IRS Batch
 
Educational Qualifications
 
Contact Details
 
Contact Number
(Mobile/Landline)
 
Email
 

Posting Profile

(If complete posting profile available on www.irsofficersonline.gov.in please indicate so and submit a copy of the same as annexure to this application.)

 
Details of experience working in International Taxation, Transfer Pricing or APA, if any
 
Reasons for applying for the advertised positions (not more than 300 words)
 
 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2023 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.