Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights April 2018 Year 2018 This

Transfer pricing adjustment - transaction between a head office ...


Indian Branch of Japanese Firm Taxed on Income from HQ Transactions Under Transfer Pricing Rules.

April 9, 2018

Case Laws     Income Tax     AT

Transfer pricing adjustment - transaction between a head office in a foreign country and its branch office in India - principle of mutuality - it is axiomatic that income of the Japanese assessee, as is relatable to the operations carried out in India through its Branch office, is chargeable to tax in India not only under the Act but also under the DTAA. - AT

View Source

 


 

You may also like:

  1. TP adjustment on account of back-to-back counter bank guarantee - TPO, by considering the rate charged by Bank of Baroda for issuance of guarantee against 100% counter...

  2. Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

  3. TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

  4. Transaction between foreign enterprise and its Indian Permanent Establishment (PE) falls within transfer pricing provisions u/s 92B. ITAT held PE must be treated as...

  5. Evasion of tax - mismatch in the e-way bill and the branch transfer invoice - levy of penalty and tax on the petitioner - The High Court observed that, even if there was...

  6. Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

  7. The High Court held that the acquisition of the trademark 'FABINDIA' during the financial year 2006-07 could not be treated as an international transaction within the...

  8. Income Taxes - Ind AS-12 of the Companies (Indian Accounting Standards) Rules, 2015 as amended

  9. Taxability in the hands of partners v/s firm - transfer of capital asset by firm to partners - There is no merit in the arguments advanced by assessee, that transfer of...

  10. Branch transfers or stock transfers - The stipulations made in the declaration form ‘F’ are nothing but giving particulars of the relevant document in support of branch...

  11. Partnership firm rendered professional services in Japan, taxes withheld there. Firm claimed foreign tax credit (FTC) which was denied by tax authorities. ITAT held that...

  12. Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

  13. Rollback of an Advance Pricing Agreement - Income-tax (Third Amendment) Rules, 2015 - CBDT issues Notification

  14. With the passage of time where India is becoming a global commercial hub with the advent of Multinational Companies new transfer pricing issues are thrown up and keeping...

  15. Rejection of branch transfer / Stock transfer of Goods - The tribunal found that the tax authority inappropriately applied a general conclusion from a small subset of...

 

Quick Updates:Latest Updates