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Category Archives: Transfer pricing
CbCR Appropriate usage guidance released by CBDT
CBDT has released the much awaited guidance on usage of Country-by-Country Reports (CbCR) informationvide Instruction No. 2/2018. The guidance pertains to the appropriate use of CbCR information. With this, the uncertainty and apprehensions on appropriate use of detailed information/ data … Continue reading
Posted in Transfer pricing
ITAT Relief on Domestic Transfer Pricing
Bangalore ITAT in Texport Overseas P. Ltd. v. DCIT[1] has held that the amendment with respect to restriction in scope of Domestic Transfer Pricing (TP) by Finance Act, 2017 is deemed to be omitted from its inception.
Posted in Transfer pricing
Secondary Adjustment in Indian TP provisions: An international best practice or needs another look?
Keeping pace with the international best practices and its commitment towards OECD BEPS Initiative/ G20, India through Finance Act 2017 has brought in certain unconventional changes in the Transfer pricing (‘TP’) & International taxation regime. After EQL, CBCReporting – BEPS … Continue reading
Posted in Transfer pricing
Tagged Indian TP provisions, Secondary Adjustment, TP provisions