Sunday, January 15, 2012

INTERNATIONAL TAXATION / TRANSFER

PRICING

  • The Delhi ITAT bench in Aithent Technologies Pvt. Ltd. vs. ITO has held that CUP method will  determine ALP of interest-free loan for transfer pricing purposes
  • The Delhi High Court in Ranbaxy Laboratories Ltd.  vs. CIT has held that AO's self-determination of ALP without referring to TPO is "erroneous & prejudicial to interests of revenue"
  • The Delhi High Court in DIT vs. Ericsson AB has  held that Profits from offshore supply of equipment & software is not taxable in India u/s 9.
  • The Bangalore ITAT bench in Genisys Integrating  Systems (India) Pvt. Ltd. vs. Dy. CIT has set out important Principles on scope, data & comparability for determining ALP for the purpose of transfer pricing

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