Transfer pricing experts and companies with international operations and subsidiaries trading with each other got a pleasant surprise when they find a CBDT notification fixing tolerance level for Assessment Year 2012-13 at 5 % in case of variation in Arm’s Length Pricing . Significant to note that as per Finance Act 2012 , the tolerance...
What is Dispute Resolution Panel (DRP) under Income tax Law ?
September 26, 2011 by
Dispute Resolution Panel (DRP ) is a collegium of three commissioners rank officers to hear the dispute between assessee and the A.O in a transfer pricing taxation matter. Finance (No.2) Bill, 2009 inserted section 144C effective from 1st day of October, 2009 in the income tax act to create an alternative dispute resolution mechanism within...
Can notional interest be taxed under transfer pricing law ?
May 18, 2010 by
Yes, under transfer pricing mechanism , there is scope of notional interest taxation. This is held by Delhi bench F in Perot Systems TSI ( India) Ltd. vs. DCIT, ITA No. 2320 to 2322/Del/08, Delhi Bench ‘F’ order dated 30.10.2009. Facts of the case The aseessee, an India company, advanced interest free loans to its 100% foreign subsidiaries....
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