Objectives & Agenda :
Transfer Pricing is one of the most litigious areas in Taxation. In this Webinar we shall look at some of the recent Judicial Precedents in Transfer Pricing Law with the aim of understanding the issues which arise and the views taken by the Authorities and the Court of Law. The Webinar discusses the facts of the case, issues and the Principles held by the Courts in each of these Decisions.
A Presentation on on 15 recent High Court Judgements (pronounced in 2015-16) on the ever-changing subject of Transfer Pricing. In some cases the High Courts have reversed the rulings of Tribunal, while in others the rulings of Tribunal have been confirmed.
Gandhi Special Tubes Limited is engaged in manufacturing and marketing of welded and seamless steel tubes of different sizes and specifications and cold formed Coupling Nuts
Military Commissions details LtCol Thomas Jasper as Detailed Defense CounselThomas (Tom) Jasper
Military Commissions Trial Judiciary, Guantanamo Bay, Cuba. Notice of the Chief Defense Counsel's detailing of LtCol Thomas F. Jasper, Jr. USMC, as Detailed Defense Counsel for Abd Al Hadi Al-Iraqi on 6 August 2014 in the case of United States v. Hadi al Iraqi (10026)
How to Obtain Permanent Residency in the NetherlandsBridgeWest.eu
You can rely on our assistance if you are ready to apply for permanent residency. Find out more at: https://immigration-netherlands.com/obtain-a-permanent-residence-permit-in-the-netherlands/.
ALL EYES ON RAFAH BUT WHY Explain more.pdf46adnanshahzad
All eyes on Rafah: But why?. The Rafah border crossing, a crucial point between Egypt and the Gaza Strip, often finds itself at the center of global attention. As we explore the significance of Rafah, we’ll uncover why all eyes are on Rafah and the complexities surrounding this pivotal region.
INTRODUCTION
What makes Rafah so significant that it captures global attention? The phrase ‘All eyes are on Rafah’ resonates not just with those in the region but with people worldwide who recognize its strategic, humanitarian, and political importance. In this guide, we will delve into the factors that make Rafah a focal point for international interest, examining its historical context, humanitarian challenges, and political dimensions.
Responsibilities of the office bearers while registering multi-state cooperat...Finlaw Consultancy Pvt Ltd
Introduction-
The process of register multi-state cooperative society in India is governed by the Multi-State Co-operative Societies Act, 2002. This process requires the office bearers to undertake several crucial responsibilities to ensure compliance with legal and regulatory frameworks. The key office bearers typically include the President, Secretary, and Treasurer, along with other elected members of the managing committee. Their responsibilities encompass administrative, legal, and financial duties essential for the successful registration and operation of the society.
A "File Trademark" is a legal term referring to the registration of a unique symbol, logo, or name used to identify and distinguish products or services. This process provides legal protection, granting exclusive rights to the trademark owner, and helps prevent unauthorized use by competitors.
Visit Now: https://www.tumblr.com/trademark-quick/751620857551634432/ensure-legal-protection-file-your-trademark-with?source=share
Car Accident Injury Do I Have a Case....Knowyourright
Every year, thousands of Minnesotans are injured in car accidents. These injuries can be severe – even life-changing. Under Minnesota law, you can pursue compensation through a personal injury lawsuit.
Objectives & Agenda :
Transfer Pricing is one of the most litigious areas in Taxation. In this Webinar we shall look at some of the recent Judicial Precedents in Transfer Pricing Law with the aim of understanding the issues which arise and the views taken by the Authorities and the Court of Law. The Webinar discusses the facts of the case, issues and the Principles held by the Courts in each of these Decisions.
A Presentation on on 15 recent High Court Judgements (pronounced in 2015-16) on the ever-changing subject of Transfer Pricing. In some cases the High Courts have reversed the rulings of Tribunal, while in others the rulings of Tribunal have been confirmed.
Gandhi Special Tubes Limited is engaged in manufacturing and marketing of welded and seamless steel tubes of different sizes and specifications and cold formed Coupling Nuts
Military Commissions details LtCol Thomas Jasper as Detailed Defense CounselThomas (Tom) Jasper
Military Commissions Trial Judiciary, Guantanamo Bay, Cuba. Notice of the Chief Defense Counsel's detailing of LtCol Thomas F. Jasper, Jr. USMC, as Detailed Defense Counsel for Abd Al Hadi Al-Iraqi on 6 August 2014 in the case of United States v. Hadi al Iraqi (10026)
How to Obtain Permanent Residency in the NetherlandsBridgeWest.eu
You can rely on our assistance if you are ready to apply for permanent residency. Find out more at: https://immigration-netherlands.com/obtain-a-permanent-residence-permit-in-the-netherlands/.
ALL EYES ON RAFAH BUT WHY Explain more.pdf46adnanshahzad
All eyes on Rafah: But why?. The Rafah border crossing, a crucial point between Egypt and the Gaza Strip, often finds itself at the center of global attention. As we explore the significance of Rafah, we’ll uncover why all eyes are on Rafah and the complexities surrounding this pivotal region.
INTRODUCTION
What makes Rafah so significant that it captures global attention? The phrase ‘All eyes are on Rafah’ resonates not just with those in the region but with people worldwide who recognize its strategic, humanitarian, and political importance. In this guide, we will delve into the factors that make Rafah a focal point for international interest, examining its historical context, humanitarian challenges, and political dimensions.
Responsibilities of the office bearers while registering multi-state cooperat...Finlaw Consultancy Pvt Ltd
Introduction-
The process of register multi-state cooperative society in India is governed by the Multi-State Co-operative Societies Act, 2002. This process requires the office bearers to undertake several crucial responsibilities to ensure compliance with legal and regulatory frameworks. The key office bearers typically include the President, Secretary, and Treasurer, along with other elected members of the managing committee. Their responsibilities encompass administrative, legal, and financial duties essential for the successful registration and operation of the society.
A "File Trademark" is a legal term referring to the registration of a unique symbol, logo, or name used to identify and distinguish products or services. This process provides legal protection, granting exclusive rights to the trademark owner, and helps prevent unauthorized use by competitors.
Visit Now: https://www.tumblr.com/trademark-quick/751620857551634432/ensure-legal-protection-file-your-trademark-with?source=share
Car Accident Injury Do I Have a Case....Knowyourright
Every year, thousands of Minnesotans are injured in car accidents. These injuries can be severe – even life-changing. Under Minnesota law, you can pursue compensation through a personal injury lawsuit.
In 2020, the Ministry of Home Affairs established a committee led by Prof. (Dr.) Ranbir Singh, former Vice Chancellor of National Law University (NLU), Delhi. This committee was tasked with reviewing the three codes of criminal law. The primary objective of the committee was to propose comprehensive reforms to the country’s criminal laws in a manner that is both principled and effective.
The committee’s focus was on ensuring the safety and security of individuals, communities, and the nation as a whole. Throughout its deliberations, the committee aimed to uphold constitutional values such as justice, dignity, and the intrinsic value of each individual. Their goal was to recommend amendments to the criminal laws that align with these values and priorities.
Subsequently, in February, the committee successfully submitted its recommendations regarding amendments to the criminal law. These recommendations are intended to serve as a foundation for enhancing the current legal framework, promoting safety and security, and upholding the constitutional principles of justice, dignity, and the inherent worth of every individual.
1. Ingersoll Rand (India) Ltd Vs DCIT [IT(TP)A
2005-06
ITAT (Bengaluru Bench) upheld the adjustment
proposed notional interest on outstanding
charging interest from non AEs in case
Fresenius Kabi India Pvt Ltd Vs DCIT [ITA No
ITAT (Pune Bench) upheld that RPM
activities are in relation to trading/distribution
made to the product, even when selling
Assessee.
Important judgments on Transfer pricing
[IT(TP)A. Nos 6 & 7/Bang/2014] – AY 2003 -04 & AY
adjustment made by Revenue wherein Revenue
outstanding receivables from AE since Assessee is
case of delay in receipt of payment.
No.235/PUN/2013] – AY 2008-09
RPM is the most appropriate method where
trading/distribution function and no value addition is
selling and marketing expenses are borne by the
Important judgments on Transfer pricing (25.08.2017)
2. ACIT Vs Akzo Nobel Car Refinishes India Pvt
05
ITAT (Delhi Bench) upheld Resale Price Method
benchmarking of international transaction
has not made any value addition to
functions is essential for comparability under
cannot be compromised even under TNMM
Teradata India Pvt. Ltd. Vs ACIT [ ITA No. 87/Del/2017]
ITAT (Delhi Bench) relied upon Kusum healthcare Pvt Ltd and ruled that working
capital adjustment takes into account the cost of Receivables from AE and no
separate adjustment is warranted.
Important judgments on Transfer pricing (18.08.2017)
Pvt Ltd [ITA No. 4096/Del/2011] – AY 2004-
Method is the most appropriate method for
transaction of purchase of goods where Assessee
goods. ITAT ruled that comparability of
under TNMM also and functional similarity
TNMM.
India Pvt. Ltd. Vs ACIT [ ITA No. 87/Del/2017] – AY 2012-13
healthcare Pvt Ltd and ruled that working
capital adjustment takes into account the cost of Receivables from AE and no
Important judgments on Transfer pricing (18.08.2017)