Qualification : Chartered Accountant
Introduction The recent decision of ITO v. Right Florists P. L. I.T.A. No. : 1336/ Kol. / 2011, deals with India™s right to tax payment made by an Indian entity (˜ICO™) to a foreign entity for online advertising services provided by the latter. Here, ICO made payments to Google Ireland and Yahoo USA (together… Read More
Tags: FCO, Foreign and Commonwealth Office, Government, Hyundai Heavy Industries, Income Tax Act, Income Tax Act 1961, India, Italy, Online advertising, Organisation for Economic Co-operation and Development, Permanent establishment, The Income-tax Act 1961, United States
Introduction We are aware that foreign exchange regulations are governed by Reserve Bank of India (˜RBI™) and income tax regulations by the Central Government. Yet, is it possible to conclude that limits laid down by RBI can be considered as Arm™s Length Price (˜ALP™) for the purposes of transfer pricing under the under Income tax… Read More
Tags: ALP, Arms Length Pricing, foreign direct investment, Income tax, India, money laundering, Reserve Bank of India, Royalties