Transfer Pricing Laws applicable to ITES/ BPO Sector explained by ITAT

CLR Editorial Notes:  The assessee, in this Transfer Pricing related case, had raised three contentious issues in support of the  contention that its charges were at Arms Length: (i) that the assessee was engaged in the low end activity of voice based call centre and that the comparables chosen by the Tranfer Pricing Officer in… Read More

Tags: ALPCommonwealth Law ReportsIndiaOECDOrganisation for Economic Co-operation and DevelopmentTPO

Turnover filter & comparisons – Important principles explained

CLR Editorial Notes: The Tribunal had to consider the following important transfer pricing issues: (i) whether a one-time and extraordinary item of expenditure (ESOP cost) debited to the assessee™s P&L A/c has to be excluded while comparing the margins, (ii) whether for the purpose of comparison of margins, the consolidated results of comparables having profit… Read More

Tags: American ExpressComparablesInfosysOECDPuneTPOtransfer pricing

Governance in Banks and Financial Institutions

(Address of Shri Anand Sinha, Deputy Governor, Reserve Bank of India, delivered on his behalf, at the L & T Management Development Centre, Lonavla on March 19, 2013) Shri Deosthalee and senior management of L & T. A very good evening. I deem it a privilege to address you this evening on ˜Governance in banks… Read More

Tags: Bank for International SettlementBusinessCadbury ReportCorporate GovernanceOECDReserve Bank of IndiaSarbanes–Oxley Act

HC order in the case of denial of benefits under Double Taxation Avoidance Agreement

CLR Editorial Notes: Hon'ble High Court of Bombay has passed an order in this particular case, saying that there is no merit in the submission by the Director of Income Tax (International Taxation) that the assessee (respondent) - an organization in Germany - cannot be considered as a taxable entity in view of the Organisation for… Read More


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