Transactional Net Margin Method

Clarifications regarding Circulars on Application of Profit Split Method

Clarification issued with Regard to Circulars on Application of Profit Split Method and on Conditions Relevant to Identify Development Centres Engaged in Contract R&D Services with Insignificant Risk; Circulars Were issued Earlier based on First Report of N Rangachary Committee on Taxation of Development Centres and IT Sector Chapter X of the Income-tax Act, 1961… Read More

Tags: Arm's length principleCBDTIncome Tax ActIndiaTaxTaxation in IndiaTransactional Net Margin Methodtransfer pricing

CBDT Circular on application of profit split method

F No. 500/139/2012 Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes (Foreign Tax and Tax Research-I Division) New Delhi, the 26th day of March, 2013 Circular No. 02 /2013 Sub: Circular on application of profit split method It has been brought to the notice of CBDT that clarification is… Read More

Tags: CBDTIncome taxIncome Tax Act 1961New DelhiPSMTaxation in IndiaTransactional Net Margin Methodtransfer pricing

Arms Length Pricing – Adjustment cannot be made to the entire entity turnover/ profits

Ratio of the Case: With relation to the Transfer Pricing regime, Arms Length Pricing should be determined on segment-wise profits & not at an entity level. In such a case, adjustments cannot be made to the entire entity turnover or profits. CLR Editorial Notes: The assessee had entered into several international transactions with its Associated… Read More

Tags: ALPArm's length principleCommonwealth Law ReportsTPOTransactional Net Margin Methodtransfer pricing

CBDT Clarification on application of Profit Split Method

F No. 500/139/2012 Government of India Ministry of Finance Department of Revenue Central Board of Direct Taxes (Foreign Tax and Tax Research-I Division) New Delhi, the 26th day of March, 2013 Circular No. 02 /2013 Sub: Circular on application of profit split method It has been brought to the notice of CBDT that clarification is… Read More

Tags: CBDTIncome taxIncome Tax Act 1961Institute of Chartered Accountants of IndiaNew DelhiTaxation in IndiaTransactional Net Margin Methodtransfer pricing

Corporate Law Referencer

Recent Articles

Recent Legal updates

Recent Gst Updates