Scope Of Transfer Pricing With Respect To Transfer Of Shares

Scope Of Transfer Pricing With Respect To Transfer Of Shares Transfer prices are defined as ˜the prices at which an enterprise transfers physical goods and intangibles or provides services to associated enterprises™[1]. Whenever a transaction takes place between two entities, whether related or unrelated, a price has to be fixed. This fixing of prices for… Read More

Tags: Finance Act 2001Income Tax Act 1961IndiaRoyal Dutch ShellTaxation in Indiatransfer pricingVodafoneVodafone India

Repeated Retrospective Amendments

It is a fundamental principle of tax law is that the law which is to be applied has to be the once which is in force during the assessment year, unless provided otherwise expressly or impliedly.[1] This applies to charging sections and other substantive provisions but does not apply to procedural provisions,[2] but a procedural… Read More

Tags: Income taxIncome Tax Act 1961Retrospective AmendmentsVodafone

Transfer Pricing controversies a tale that is not a fairy one

1. Introduction Since its introduction in the Finance Bill 2001, transfer pricing provisions/regulations (TP regulations) have been a matter of huge debate & consequentially tremendous amount of litigations. Lack of conceptual clarity & high level of subjectivity in application of rules & various methods collated with strain of meeting higher revenue targets has added salt… Read More

Tags: DelhiGlaxoSmithKlineIncome taxIndiaMultinational corporationNokiatransfer pricingVodafone

Implications of Transfer Pricing in Cross-Border Deals

Ratio of the Case: Domestic Leg of a Global Sale of business not covered under TP regime if terms not stated by parent Associated Enterprise CLR Editorial Notes: Eastman Kodak, USA, entered into an agreement with Onex Healthcare Holdings, USA, for the global sale by Eastman of the medical business to Onex for a consideration of… Read More

Tags: Eastman KodakIndiaLG Electronicstransfer pricingVodafone

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