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 ...
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 ...
16 January, 2014
The issue of interest on delayed payments, since the payer is to benefit from interest free funds has given rise to many disputes on whether adjustment should be made and if so what would be a reasonable rate at which such interest will be deemed to have been earned. In Dania Oro Jeweler Pvt Ltd v. ITO [ITA(TP) 6827/Mum/2012] ITAT Mumbai held that since there was considerabl...
9th May, 2013
In a recent order, the Income Tax Appellate Tribunal (ITAT), Mumbai had the occasion to go into the question of what is or is not an international transaction. The parent company of the appellant had sold its imaging business, globally. As part of this, but on facts, independently, the Indian subsidiary sold its medical imaging business to the subsidiary of the foreign buyer. Th...
Affiliates of Multi National Enterprises (‘MNEs’), in the recent past, are moving more towards functioning independently from their parent, operational and financial. The freedom given in managing their own affairs in growing economies like India, has helped the affiliates to grow faster in the local markets. However, ...
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