Month: June 2013

CBDT Press Release Withdrawing / Amending Circulars On Transfer Pricing

The CBDT has issued a Press Release dated Nil stating that Circular No.2/2013 dated 26.03.2013 (Circular on application of profit split method) has been rescinded and that Circular No. 3 dated 26.03.2013 (Circular on conditions relevant to identify Development Centres engaged in contract R&D services with insignificant risk) has been amended and reissued with a view to clear all ambiguities in the matter

Modifications In Transfer And Posting Orders By CBDT

The CBDT has carried out a series of modifications to the earlier transfer and posting orders

Transfers And Postings Of Joint/ Additional CITs (Mumbai)

Vide Order No. 1 dated 20.06.2013 the Chief Commissioner of Income-tax, Mumbai, has ordered the transfer and posting of 48 officers in the grade of Joint/ Additional Commissioners of Income-tax (Mumbai Region) with immediate effect

Change In Constitution Of Bombay High Court’s Tax Bench w.e.f. 24.06.2013

Change In Constitution Of Bombay High Court’s Tax Bench w.e.f. 24.06.2013

Transfers And Postings Of Assistant/ Deputy CITs (Mumbai)

Vide Order No. 1 dated 18.06.2013 the Chief Commissioner of Income-tax, Mumbai, has ordered the transfer and posting of 148 officers in the grade of Assistant/ Deputy Commissioners of Income-tax (Mumbai Region) with immediate effect

India Will Have The Best Tax Regime In The World: New CBDT Chief

The CBDT has issued Office Order No. 127/2013 dated 14.06.2013 stating that the President of India has appointed Ms. Sudha Sharma as Chairperson of the Central Board of Direct Taxes (CBDT) in the pay scale of Rs. 80,000 (fixed) with the status of Special Secretary to the Government. Upon taking charge, Ms. Sudha Sharma addressed a letter in which she pointed out that that the guiding principles of “non-intrusive” and “non-adversarial” tax administration as laid down by the Finance Minister has to be followed by the department in its day-to-day working. She also emphasized that the department has to create an environment for voluntary compliance. She pointed out that as tax collectors of the country, the tax department has a pivotal role to play in national growth and has to achieve the huge target of budget collection. She emphasized that the potential for tax collection is much higher given that there is a base of only about 3.5 crore assesses, a mere 2.9% of the national population, of which only 42,800 declares annual income over Rs. 1 crore. She stated that while the endeavour would be to promote voluntary compliance and provide hassle-free service to the honest tax payers, focus would need to be kept on non-filers and stop-filers in order in order to enhance the tax base and augment tax collection. She also stated that the department is aiming at achieving a tax regulation regimen in India which can match the best in the world

Transfers And Postings Of Commissioners of Income-tax

Vide Order No. 106 of 2013 dated 14.06.2013, the CBDT has ordered the transfer & posting of several officers in the grade of Commissioner of Income-tax with immediate effect

United Nations Practical Manual on Transfer Pricing

The United Nations has released a publication titled “Practical Manual on Transfer Pricing”. The Manual contains valuable discussion on a number of important topics. For instance, there is a detailed discussion on the types of transfer methods available (such as CUP, TNMM etc) and their respective merits and demerits. Practical examples and case studies have also been given to explain in what circumstances a particular method is suitable. There is also detailed discussion on how comparables should be selected and how a comparability analysis should be conducted. There is also detailed discussion on the transfer pricing implications of marketing intangibles (trade marks, technical know-how etc) which becomes very relevant in the light of L.G.Electronics vs. ACIT 140 ITD 41 (SB). There is also a write-up on the law & practices being followed in India and other countries

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