25 January 2017
The assessee is engaged in the business of manufacture and sale of polished diamonds. The assessee entered into an international transaction with a Belgian Entity by name Blue Gems BVBA. The Assessing Officer (AO) was of the view that the said entity would qualify to be Associated Enterprises (AEs) on the ground that the assessee and Blue ...
17 July, 2015
Corporate guarantees have often been examined for transfer pricing adjustment. While there are number of judgements on how to determine the ALP and that bank rates are not to be applied, whether the transaction is an international transaction is always intriguing.
ITAT, Hyderabad in its decision in Four Soft P Ltd v. DCIT...
11 June, 2015
To come within the ambit of transfer pricing, there has to be an international transaction. The two requirements of international transaction are that there must be a transaction between associated enterprises and either or both parties should be non-residents (prior to the amendment by Finance Act, 2014). In an interesting decision [Novo ...
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