Home Highlights March 2019 Year 2019 This

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1. TP Adjustment Transaction of slump sale between the subsidiaries of Foreign Holding Company - To be considered as an international transaction or not - The meaning of...

2. Amendment of section 92D. - TPA - maintenance and keeping of information and document by persons entering into an international transaction or specified domestic...

3. TP Adjustment - As per the provisions of aforesaid Rule, the ‘other method’ shall be the method which takes into account the price which has been or would have been...

4. Determination of transaction - statutory change to section 92CA - AO is now bound by the order of the TPO on the computation of the arm’s length price of an...

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

6. Penalty u/s 271BA - non- filing of report as required u/s 92E - Once we hold that the assessee and the alleged AE could not be treated as associated enterprises, and...

7. Transfer pricing adjustment - arm‘s length pricing of international transactions - Advertising / Marketing and Promotion Expenses - international transaction - Domestic...

8. TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the...

9. TP Adjustment - international transactions u/s. 92B or not - In absence on any such agreement, the first and primary condition of holding the transaction in question as...

10. Permission to a person resident outside India to enter into exchange traded currency derivatives

11. All persons (other than Individuals) entering into a transaction of ₹ 2.50 Lakhs or more shall be required to obtain PAN including its key persons (officers)

12. Transfer pricing adjustment – When the indent/commission transaction with the associated enterprises is to be benchmarked, the same should be done with indent/...

13. Transfer pricing adjustment - agreement was between the Indian PSU and the Indian subsidiary of two non resident companies - transaction, cannot be presumed to be...

14. Transaction between the head office of the assessee and its branch in India was a transaction between the principal and principal. In law, there cannot be a valid...

15. TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from...