Rule 10B(1)(e)(iii) provides that an adjustment should be made to the profit margin of independent comparable companies to take into account the differences in functions and risks. International commentaries on transfer pricing also recognize that controlled and uncontrolled transactions are comparable only when adjustments with respect to significant differences between
A Brief About Black Money Law (Bml)
This law applies only to Resident and Ordinarily resident of India (ROR). The objective of the law is to bring back into India, the money held abroad by Indian residents. It is applicable from 01-07-2015. BML applies only to foreign sourced income and assets which are liable to Indian Tax
Significance Of Rapport Building With Clients
It is important to develop good working relationships with clients to ensure effective audit engagement. To be a successful auditor it is essential to build rapport with the audit client. There are several approaches and techniques related to rapport building. Auditors can adopt certain means in the course of their
Indian Transfer Pricing (‘TP’) – Changing Trends
The TP Regulations in India were introduced in 2001 under the anti-abuse provisions of the Income-tax Act, 1961 (ITA) largely modelled on the TP principles followed by the organisation for Economic Cooperation and development (OECD) and aimed to ensure that transactions between group companies adhere to the arm’s length standard.
Foreign Direct Investments In Limited Liability Partnership
Limited Liability Partnerships (for brevity referred as ‘LLP’) is one of the emerging trends among the types of vehicles available for conduct of business or profession. LLP’s are governed by Limited Liability Partnership Act, 2008. This article aims at understanding the overview of regulatory requirements when Foreign Direct Investments(for brevity
Copyright – Sale Vs Deemed Sale Vs Service
The taxability of intangibles in the sphere of indirecttaxation is often ambiguous and litigation prone. The whole country has witnessed the decision of the apex court in the case of Tata Consultancy Services vs 1 State of Andhra Pradeshwherein it was held that intangible intellectual property right in the computer
Board’s Report Under Companies Act, 2013 – Contents Thereof – An Analysis
Preparation of Board’s Report under the Companies Act, 2013, can be co-related to putting a jig-saw puzzle in place, because of the quantum of information that needs to be obtained and put in place forthe same. It is a welcome move that there are lot of disclosures/information which are required
Accounting Standards – IND AS And IFRS Concept
What and Why Ind AS: To know what and why Ind AS, we need to first understand what and why IFRS: IFRS (International Financial Reporting Standards) International Financial Reporting Standards (IFRS): International Financial Reporting Standards (IFRS) are designed as a common global language for business affairs so that company accounts
Transfer Pricing Assessment – Practical Views
Section 92CA of the Indian Income Tax Act provides that an Assessing Officer may make a reference to a Transfer Pricing Officer (TPO) for computation of arm’s length price (ALP). In India, TP audits are conducted by specialist officers notified as Transfer Pricing Officers (‘TPO’) by the CBDT. The DGIT
Constitutional Validity Of Service Tax On Restaurant Services – An Incisive Analysis
Introduction: Ever since the introduction of the service tax levy on Restaurant services (effective from 01.05.2011), its constitutional validity turned out as contentious issues. The reason being that State Governments are imposing VAT on entire consideration received towards food supply over the last two decades by placing reliance on Article