The Central Board of Direct Taxes (CBDT) on 20th July, 2018 released a notification stating the amendments/key changes in the Tax Audit Form 3CD. They shall come into force from the 20th day of August, 2018. CLICK HERE to Download the Notification.
Hello Readers, Hope you have read the previous parts. Click here to see the previous parts. FAR Analysis Functions, Assets and Risk (‘FAR’) analysis is an analysis of the functions performed, taking into account assets used and risks assumed by associated enterprises (AEs) in controlled transactions. A method of finding and organizing facts about a business in terms of the functions performed, assets used (including intangible property) and risks assumed by such business to: Identify how they are divided among the AEs; and Ø [...]
The centre government has launched Income Tax Informants Reward Scheme, 2018, after superseding the 2007 award scheme, under which a person can get reward up to Rs 50 lakh for giving specific information about substantial evasion of tax on income or assets in India. Also, those informing the government about 'undisclosed black money' stashed abroad can win awards up to Rs 5 crore. Anyone who informs about Benami properties can get awards up to Rs 1 crore. The scheme comes [...]
If you are a CA Student, then read it….It's been more than 7-8 months for me to be an user of this app. Being a CA Student, i was very much active in replying to queries related to Board of Studies, Articleship, CPT, IPCC, Final subject wise issues. But, there is a particular trend which is being followed by CA Students which is not good for them. let me explain what is it…. •If someone didn't get his articleship letter then he [...]
Hello Readers, Hope you have read the previous parts. Click here to see the previous parts. Let’s proceed further…. Computation of ALP: I had already discussed CUP method of computation of ALP, so now let us discuss other parts: Method 2: Resale Price Method The resale price method (RPM) is a method which compares the gross margins (i.e. gross profit over sales) earned in transactions between related and unrelated parties for the determination of the ALP. The RPM requires high level of functional comparability and [...]
Hello readers, hope you have read the previous parts in which we had covered the basics of international taxation laws and the concept of associated & deemed associated enterprises. Let’s proceed further….. International Transaction An international transaction means: a transaction between two or more associated enterprises, either or both of whom are nonresidents; and transaction in the nature of: sale/ purchase/ lease of tangible property; or sale/ purchase/ lease of intangible property; or provision of services; or lending/borrowing money; or any other [...]
Hello Readers, Yesterday we have discussed about the basics of international taxation and covered basic aspects regarding the Arm Length’s Price principles and the reason behind the introduction of transfer pricing provisions in the Income Tax Act, 1961. Hope you have gone through it. Let’s proceed further and today we will cover other aspects of transfer pricing. **TP means Transfer Pricing **ALP means Arm Length Price Section 92: COMPUTATION OF INCOME FROM TRANSACTION WITH NON-RESIDENT Section 92 provides that any income arising from an “international transaction” [...]
THE PNB FRAUD The hot topic of these days is PNB scam. Everyone is sharing on social platforms that PNB is involved in the fraud of Rs. 11,500 crores approx. but everyone is not aware about the way it has happened. So, let us discuss about the one of the biggest scams of the country, The PNB Fraud. **For the purpose of this article, Foreign Bank means “Foreign branch of an Indian Bank” Before proceeding further, we should know about the LoU i.e. [...]
Base Erosion & Profit Shifting – A Global Challenge Meaning: “Recently more and more enterprises organised abroad by American firms have arranged their corporate structures aided by artificial arrangements between parent and subsidiary regarding intercompany pricing, the transfer of patent licensing rights, the shifting of management fees, and similar practices in order to reduce sharply or eliminate completely their tax liabilities both at home and abroad.” So, Base erosion and profit shifting (BEPS) refers to tax avoidance strategies that exploit gaps and [...]
Section 24, Power of Securities and Exchange Board to regulate issue and transfer of securities, etc The provisions of this section specifically bring the Securities & Exchange Board of India (SEBI) into the big picture. As per this section: In case of listed companies and the companies which intend to get their securities listed on any recognized stock exchange in India, The matters related to Issue and transfer of securities and Non-payment of dividend, Shall be administered by the Securities and Exchange Board [...]
