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The Indian domestic tax laws contain certain provisions which provide differential tax treatment in transactions involving residents and non-residents.

The tax courts in India have been increasingly attempting to provide clarity on recurring transfer pricing issues such as payment of royalty, functional characterization, etc.

The Mumbai Bench of the Income Tax Appellate Tribunal (Tribunal) ruled in favour of Tata Industries Limited (Taxpayer) on the invocation of Section 93 of the Income Tax Act, 1961 (IT Act).

In a recent ruling1, the Hon'ble Supreme Court has reversed the decision of Karnataka High Court2 which held that determination of arm's length price (‘ALP') by the Income Tax Appellate Tribunal (‘Tribunal') is final and cannot be subject matter of appeals before High Court.

Transfer pricing refers to the pricing strategy in play when there is transfer of goods/ services between associated enterprises.

Diageo India Private Limited (the taxpayer) is a wholly owned subsidiary of Selvic Netherlands BV, which is a part of Diageo group. The taxpayer is engaged in the business of manufacturing and distribution of alcoholic beverages.

We are pleased to present the latest edition of Tax Street - our newsletter that covers all the key developments and updates in the realm of taxation in India and across the...

We are pleased to present the latest edition of Tax Street – our newsletter that covers all the key developments and updates in the realm of taxation in India and across the globe for the month of January 2021.

With the increasing globalization, cross-border transactions are integral to modern business strategy.

Growth: The Economic Survey 2024-25 projected a real GDP growth for FY26 between 6.3% to 6.8%.

In the recent past, there have been significant tax controversies in India which have been closely monitored around the globe by Multi-National Enterprises (MNEs), tax administrators...

We are pleased to present the latest edition of Tax Street – our newsletter that covers all the key developments and updates in the realm of taxation in India and across the globe for the month of April 2025.

Transfer pricing adjustment cannot be made in a case where the tax rate in the country of the Associated Enterprise is higher than the Indian rate...

In the contemporary context of global business expansion, multinational enterprises (MNEs) are increasingly dependent on offshore subsidiaries located in India to leverage its extensive talent pool, cost efficiencies, and expanding market potential.

Cross-border service delivery is central to the operating model of most GCCs. The global capability center may be operating to strengthen finance, technology, analytics, procurement, or back-office functions for overseas group entities.

The Tax Deducted at Source ("TDS") mechanism is one of the most preferred methods of revenue collection among countries across the world.

The rapid global scale outbreak of the novel coronavirus (COVID-19) has taken the world by storm.