Taurian Iron & Steel Co. Private Limited, during previous year relevant to the assessment year under review, advanced share application money to its wholly owned subsidiary in South Africa...

No TP adjustment on imports at lesser value under predatory pricing policy to capture market.

Recently the Delhi High Court in the case of Steria India Ltd. relying on the most favored nation clause under the India - France Double Taxation Avoidance Agreement held that payments made by an Indian company to a French company for management services does not constitute Fees for Technical Services.

The GST council managed to arrive at a consensus on how to compensate the state for losses they incur on account of tax reform that subsume various state and central levies.

The GST Council in its 36th Council Meeting held on 27 July 2019 via video conferencing has made following recommendations:

Recently the Delhi High Court's in the case of CUB Pty Ltd granted relief to multinationals licensing and registering their intellectual property in India and held that the situs of an intangible asset like IPRs, shall be the situs of the owner of such asset.

Delhi Tribunal estopped Assessing Officer to assume Transfer Pricing Officer's power; Held that the arm's length price determined by the TPO cannot be disregarded by the AO

The Tribunal bore on the reliance placed by the taxpayer on its Advance Pricing Agreement arrangement with Revenue Authorities for the disputed transaction, and thereby disdained the TPO's determination of ALP for payment of management fees at ‘Nil' on ground of absence of concrete evidences

The High Court allowed the TP assessment proceedings to carry on further despite keeping the debate open on analyzing shareholding pattern of the directors and their relatives for examining the applicability of Domestic TP provisions

The Taxpayer reiterated the fact that it never had an expectation to earn interest income from its subsidiary but to benefit itself.

Transaction amongst taxpayer and Indian permanent establishment of its overseas group entity does not fall within the ambit of "international transaction" and thus, is not subject to Indian Transfer Pricing provisions

M/s. Faurecia Automotive Holding (assessee), a tax resident of France, received certain amount from Faurecia India towards reimbursement of salary cost of an expatriate seconded to Faurecia India and also for rendition of certain services.

Mori Seiki Co. Ltd., operating as a Branch office of Mori Seiki- Japan in India ["India BO"], is primarily engaged in selling machine tools manufactured by the HO in India.

Expenses incurred by Indian entity for setting up its overseas subsidiary (pre-incorporation expenses) cannot be relegated as "international transaction" and shall consider being a "shareholder activity".

The Income Tax Appellate Tribunal ruled that income earned by Rackspace, US Inc. (assessee) did not qualify as Royalty or Fee for Technical Services but business income, not taxable in India in the absence of Permanent Establishment ...

The Income Tax Appellate Tribunal, Cochin ruled that Short Term Capital Gains earned by Sri K.E. Faizal (assessee) through alienation of units of ‘equity oriented mutual funds' are not taxable in India in view of ...

Within a fortnight of President of India signing off on 122nd Constitutional Amendment Bill to introduce the Goods and Services Tax, work on the succeeding stages has been initiated.

On 29 January 2013, a scheme for amalgamation of SPIL and taxpayer was approved by the High Court with effect from 1 April 2012.

GST, which is considered as biggest tax reform since 1947 which seeks to replace a slew of taxes and levies in 29 states and aims to simplify and harmonise the indirect tax regime in the country.

Aggrieved by the same, both parties filed an appeal before the Income Tax Appellant Tribunal ("the ITAT"/ "the Tribunal").