This document provides a summary of various tax and accounting news from abm & associates, a chartered accountants firm. Key points include:
- Payments made to Google and Yahoo for online advertisements were ruled not taxable in India as websites alone do not constitute a permanent establishment and the services provided were automated with no human intervention.
- Changes were announced to India's consolidated FDI policy guidelines effective April 25, 2013, including allowing 49% foreign airline investment in domestic carriers and raising FDI caps in various sectors.
- TDS rates for the financial year 2013-2014 were outlined for various types of payments to residents.
- The tribunal ruled that UPS systems qualify for the higher 80%
Newsletter on daily professional updates- 23/01/2020CA PRADEEP GOYAL
I believe that the greatest crime is to learn something that can significantly benefit other people, yet share it with no one
Here is your Daily dose of professional updates 23.01.2020
Building bridges - A newsletter from Grant Thornton’s Indo-Japan Desk - Volume 1Misbah Hussain
The newsletter aims to elucidate the key milestones in the ever evolving relationship of India and Japan, and provide insights to dynamic businesses in India and Japan on key developments.
“Knowledge is like a garden; if it is not cultivated, it cannot be harvested.” Hi Good morning, attached today's newsletter dated 17.09.2020. have a great day ahead
Greetings
Union budget for FY 2018-19 was presented by Hon'ble Finance Minister Shri. Arun Jaitely . As most of you are aware, this budget is unique being presented before election in 2019
Equalisation Levy - Sandeep JhunjhunwalaSS Industries
The document discusses the introduction and development of equalization levy globally and in India. It provides background on how equalization levy began as a response to tax challenges from the digital economy. Key points include:
- India was the first country to introduce an equalization levy under domestic law based on OECD recommendations. It is different from an income tax and takes the form of a final withholding tax.
- The levy applies to consideration received by non-residents for online advertising and digital services from Indian residents and businesses at a rate of 6%.
- Key judicial precedents in India upheld that payments for digital advertising were not royalty or FTS and were not taxable in the absence of
Newsletter on daily professional updates- 23/01/2020CA PRADEEP GOYAL
I believe that the greatest crime is to learn something that can significantly benefit other people, yet share it with no one
Here is your Daily dose of professional updates 23.01.2020
Building bridges - A newsletter from Grant Thornton’s Indo-Japan Desk - Volume 1Misbah Hussain
The newsletter aims to elucidate the key milestones in the ever evolving relationship of India and Japan, and provide insights to dynamic businesses in India and Japan on key developments.
“Knowledge is like a garden; if it is not cultivated, it cannot be harvested.” Hi Good morning, attached today's newsletter dated 17.09.2020. have a great day ahead
Greetings
Union budget for FY 2018-19 was presented by Hon'ble Finance Minister Shri. Arun Jaitely . As most of you are aware, this budget is unique being presented before election in 2019
Equalisation Levy - Sandeep JhunjhunwalaSS Industries
The document discusses the introduction and development of equalization levy globally and in India. It provides background on how equalization levy began as a response to tax challenges from the digital economy. Key points include:
- India was the first country to introduce an equalization levy under domestic law based on OECD recommendations. It is different from an income tax and takes the form of a final withholding tax.
- The levy applies to consideration received by non-residents for online advertising and digital services from Indian residents and businesses at a rate of 6%.
- Key judicial precedents in India upheld that payments for digital advertising were not royalty or FTS and were not taxable in the absence of
Newsletter on daily professional updates- 26th September 2019CA PRADEEP GOYAL
Knowledge is like a garden; if it is not cultivated, it cannot be harvested
Here is your Daily dose of professional updates in newsletter form- 26th September 2019
The new law provides for an equalisation levy of 6% on the amount of consideration received, or receivable on specified services carried on by a non-resident not having a permanent establishment in India.
TransPrice Times 16th - 30th April 2017Akshay KENKRE
Dear Members,
We are pleased to present TransPrice Times for the second fortnight of April 2017.
Issues on permanent establishments, brand development, deemed international transactions and royalty payments are discussed in this periodical.
Newsletter on daily professional updates- 23rd September 2019CA PRADEEP GOYAL
The greatest enemy of knowledge is not ignorance, it is the illusion of knowledge
Have a look, here is your Daily dose of professional updates in newsletter form- 23st September, 2019
TransPrice Times - October & November 2017Akshay KENKRE
Dear Members,
We are pleased to present TransPrice Times for the month of October & November 2017.
This periodical covers key court rulings on the issues of entity level approach over transactional approach, treaty benefits, receivables from an associated enterprise, royalty & TDS provisions, and real income theory. Apart from this, recent news relating to India's stand on MAP and bilateral APA applications has been discussed in the periodical.
Thank You and Happy Reading!!
Newsletter on daily professional updates- 07/02/2020CA PRADEEP GOYAL
Knowledge is a social process.
That means no one person can take responsibility for collective knowledge.
Here is your Daily dose of professional updates 07.02.2020
Dear Members,
We are pleased to present TransPrice Times for the second fortnight of June 2017.
This periodical broadly covers important rulings, addressing different key transfer pricing issues related to treatment of royalties received from an Indian company & foreign company's viewpoint, and service PE.
Incorporation of Limited Liability Partnership (LLP) and conversion into CompanyDVSResearchFoundatio
Objectives & Agenda :
One of the convenient forms of running an organisation is the Limited Liability Partnership (LLP). It has similar features as that of a Company and has various advantages. With the advent of ease of doing business initiative, incorporation of LLP has become simple. The webinar covers the procedure for incorporation of an LLP under the LLP Act, 2008 read with LLP Rules, 2009 and its conversion into Company as per the provisions of the Companies Act, 2013.
Budget synopsis by Blue Consulting (March 19th 2012)Chandan Goyal
The document provides a synopsis of direct and indirect tax proposals from the Indian budget presented on March 16, 2012. Key direct tax proposals include no change in corporate tax rates, removal of cascading dividend distribution tax, and increased thresholds for tax audits and presumptive taxation. International tax proposals focus on advance pricing agreements, transfer pricing regulations, and clarifications overriding previous court judgments. Personal tax proposals include an increased basic exemption limit and widening of the 20% tax slab.
The Served From India Scheme (SFIS) provides duty credit scrips to Indian service providers equivalent to 10% of their free foreign exchange earnings from export of eligible services. Eligible services include a wide range of business, financial, health, tourism and other services. Service providers must have minimum annual foreign exchange earnings of Rs. 10 lakhs to qualify. Duty credit scrips can be used for import of capital goods, office equipment, and consumables related to the service business. The scheme aims to promote growth in export of services from India.
This document summarizes three writ petitions filed challenging the denial of benefits under India's Served from India Scheme (SFIS) to certain companies. The petitioners (Yum Restaurants, Nokia Solutions, and E.I. DuPont) had previously received SFIS benefits but were later denied on the grounds that as subsidiaries of foreign companies, they did not further the objective of creating an Indian brand. The document discusses the legal framework around India's foreign trade policy, the SFIS scheme, and the decisions of the Policy Interpretation Committee that led to denying the petitioners SFIS benefits based on their status as foreign subsidiaries. It also provides background facts on each petitioner's operations and claim for SFIS benefits.
Newsletter on daily professional updates- 17th September 2019CA PRADEEP GOYAL
In today's environment, hoarding knowledge ultimately erodes your power. If you know something very important, the way to get power is by actually sharing it.
Here is your Daily dose of professional updates in newsletter form- 17th September 2019
The document discusses India's services export promotion council (SEPC). It defines the four modes of exporting services: cross-border, consumption abroad, commercial presence, and movement of natural persons. It outlines SEPC's role in promoting India's service exports and lists the 14 sectors it covers, including healthcare, tourism, and consulting. Major export destinations and producers are also mentioned.
A crisp analysis of Service Export from India SchemeChandan Goyal
The document provides an overview of India's Service Exports from India Scheme (SEIS). Key points:
- SEIS replaces the previous Served from India Scheme to encourage export of notified services from India.
- It provides duty credit scrips worth 3-5% of net foreign exchange earnings to eligible service providers exporting via two specified modes.
- Eligible services and service providers must meet minimum net foreign exchange thresholds. Rewards can be used for customs/excise/service tax duties.
- The scheme aims to rationalize incentives and remove restrictions of the previous scheme to boost exports of notified services.
The document provides a summary of tax updates for May 2019 from various sources. It discusses changes made by the Central Board of Direct Taxes including notifications issued and draft forms released. It also summarizes international cooperation efforts by the UN and OECD on tax matters. Finally, it summarizes several domestic tax case laws from the Supreme Court and various High Courts.
Newsletter on daily professional updates- 07/01/2020CA PRADEEP GOYAL
“If four things are followed –
having a great aim,
acquiring knowledge,
hard work, and
perseverance –
then anything can be achieved.”
Here is your Daily dose of professional updates 07.01.2020
This document is a newsletter covering topics related to indirect taxes, direct taxes, corporate laws, insolvency and bankruptcy, and the economy. It provides updates on notifications, circulars, and legal cases. Some key updates include a clarification on the provision allowing unconditional exemption from GST collection, a facility to download details of Form GSTR-9, and guidance on manufacturing operations in special warehouses. Case summaries relate to GST applicability on construction lifts and availability of input tax credit. The newsletter also shares announcements from regulatory bodies and reports on recent legal, policy, and economic developments.
Key Takeaways:
Common Issues in Transfer Pricing
Issues relating to Transactions and Specified Items
Issues relating to Comparable and Assesments
Issues arising pursuant to Covid-19
Service Export from India Scheme (SEIS)Vishal Tayal
This document provides an overview of India's Service Export from India Scheme (SEIS), which aims to encourage service exports from India by providing duty credit scripts. It outlines the eligibility criteria, benefits, and restrictions of the scheme. Eligible service providers can receive duty credit scripts equivalent to 3-5% of their net foreign exchange earnings from specified services exported to other countries. The document lists the specified services eligible for rewards under the scheme and provides frequently asked questions about applying for and using the duty credit scripts. It also describes the role professionals can play in maximizing benefits under the scheme for eligible service providers.
The document provides guidance on conducting effective searches on Project Muse to find articles relevant to a class project, including how to frame a topic with keywords and synonyms, how to construct searches using Boolean operators and other tools, and how to evaluate results and cite sources properly. The objective is to guide students on searching Project Muse to locate useful information for their class projects and cite any information used.
Newsletter on daily professional updates- 26th September 2019CA PRADEEP GOYAL
Knowledge is like a garden; if it is not cultivated, it cannot be harvested
Here is your Daily dose of professional updates in newsletter form- 26th September 2019
The new law provides for an equalisation levy of 6% on the amount of consideration received, or receivable on specified services carried on by a non-resident not having a permanent establishment in India.
TransPrice Times 16th - 30th April 2017Akshay KENKRE
Dear Members,
We are pleased to present TransPrice Times for the second fortnight of April 2017.
Issues on permanent establishments, brand development, deemed international transactions and royalty payments are discussed in this periodical.
Newsletter on daily professional updates- 23rd September 2019CA PRADEEP GOYAL
The greatest enemy of knowledge is not ignorance, it is the illusion of knowledge
Have a look, here is your Daily dose of professional updates in newsletter form- 23st September, 2019
TransPrice Times - October & November 2017Akshay KENKRE
Dear Members,
We are pleased to present TransPrice Times for the month of October & November 2017.
This periodical covers key court rulings on the issues of entity level approach over transactional approach, treaty benefits, receivables from an associated enterprise, royalty & TDS provisions, and real income theory. Apart from this, recent news relating to India's stand on MAP and bilateral APA applications has been discussed in the periodical.
Thank You and Happy Reading!!
Newsletter on daily professional updates- 07/02/2020CA PRADEEP GOYAL
Knowledge is a social process.
That means no one person can take responsibility for collective knowledge.
Here is your Daily dose of professional updates 07.02.2020
Dear Members,
We are pleased to present TransPrice Times for the second fortnight of June 2017.
This periodical broadly covers important rulings, addressing different key transfer pricing issues related to treatment of royalties received from an Indian company & foreign company's viewpoint, and service PE.
Incorporation of Limited Liability Partnership (LLP) and conversion into CompanyDVSResearchFoundatio
Objectives & Agenda :
One of the convenient forms of running an organisation is the Limited Liability Partnership (LLP). It has similar features as that of a Company and has various advantages. With the advent of ease of doing business initiative, incorporation of LLP has become simple. The webinar covers the procedure for incorporation of an LLP under the LLP Act, 2008 read with LLP Rules, 2009 and its conversion into Company as per the provisions of the Companies Act, 2013.
Budget synopsis by Blue Consulting (March 19th 2012)Chandan Goyal
The document provides a synopsis of direct and indirect tax proposals from the Indian budget presented on March 16, 2012. Key direct tax proposals include no change in corporate tax rates, removal of cascading dividend distribution tax, and increased thresholds for tax audits and presumptive taxation. International tax proposals focus on advance pricing agreements, transfer pricing regulations, and clarifications overriding previous court judgments. Personal tax proposals include an increased basic exemption limit and widening of the 20% tax slab.
The Served From India Scheme (SFIS) provides duty credit scrips to Indian service providers equivalent to 10% of their free foreign exchange earnings from export of eligible services. Eligible services include a wide range of business, financial, health, tourism and other services. Service providers must have minimum annual foreign exchange earnings of Rs. 10 lakhs to qualify. Duty credit scrips can be used for import of capital goods, office equipment, and consumables related to the service business. The scheme aims to promote growth in export of services from India.
This document summarizes three writ petitions filed challenging the denial of benefits under India's Served from India Scheme (SFIS) to certain companies. The petitioners (Yum Restaurants, Nokia Solutions, and E.I. DuPont) had previously received SFIS benefits but were later denied on the grounds that as subsidiaries of foreign companies, they did not further the objective of creating an Indian brand. The document discusses the legal framework around India's foreign trade policy, the SFIS scheme, and the decisions of the Policy Interpretation Committee that led to denying the petitioners SFIS benefits based on their status as foreign subsidiaries. It also provides background facts on each petitioner's operations and claim for SFIS benefits.
Newsletter on daily professional updates- 17th September 2019CA PRADEEP GOYAL
In today's environment, hoarding knowledge ultimately erodes your power. If you know something very important, the way to get power is by actually sharing it.
Here is your Daily dose of professional updates in newsletter form- 17th September 2019
The document discusses India's services export promotion council (SEPC). It defines the four modes of exporting services: cross-border, consumption abroad, commercial presence, and movement of natural persons. It outlines SEPC's role in promoting India's service exports and lists the 14 sectors it covers, including healthcare, tourism, and consulting. Major export destinations and producers are also mentioned.
A crisp analysis of Service Export from India SchemeChandan Goyal
The document provides an overview of India's Service Exports from India Scheme (SEIS). Key points:
- SEIS replaces the previous Served from India Scheme to encourage export of notified services from India.
- It provides duty credit scrips worth 3-5% of net foreign exchange earnings to eligible service providers exporting via two specified modes.
- Eligible services and service providers must meet minimum net foreign exchange thresholds. Rewards can be used for customs/excise/service tax duties.
- The scheme aims to rationalize incentives and remove restrictions of the previous scheme to boost exports of notified services.
The document provides a summary of tax updates for May 2019 from various sources. It discusses changes made by the Central Board of Direct Taxes including notifications issued and draft forms released. It also summarizes international cooperation efforts by the UN and OECD on tax matters. Finally, it summarizes several domestic tax case laws from the Supreme Court and various High Courts.
Newsletter on daily professional updates- 07/01/2020CA PRADEEP GOYAL
“If four things are followed –
having a great aim,
acquiring knowledge,
hard work, and
perseverance –
then anything can be achieved.”
Here is your Daily dose of professional updates 07.01.2020
This document is a newsletter covering topics related to indirect taxes, direct taxes, corporate laws, insolvency and bankruptcy, and the economy. It provides updates on notifications, circulars, and legal cases. Some key updates include a clarification on the provision allowing unconditional exemption from GST collection, a facility to download details of Form GSTR-9, and guidance on manufacturing operations in special warehouses. Case summaries relate to GST applicability on construction lifts and availability of input tax credit. The newsletter also shares announcements from regulatory bodies and reports on recent legal, policy, and economic developments.
Key Takeaways:
Common Issues in Transfer Pricing
Issues relating to Transactions and Specified Items
Issues relating to Comparable and Assesments
Issues arising pursuant to Covid-19
Service Export from India Scheme (SEIS)Vishal Tayal
This document provides an overview of India's Service Export from India Scheme (SEIS), which aims to encourage service exports from India by providing duty credit scripts. It outlines the eligibility criteria, benefits, and restrictions of the scheme. Eligible service providers can receive duty credit scripts equivalent to 3-5% of their net foreign exchange earnings from specified services exported to other countries. The document lists the specified services eligible for rewards under the scheme and provides frequently asked questions about applying for and using the duty credit scripts. It also describes the role professionals can play in maximizing benefits under the scheme for eligible service providers.
The document provides guidance on conducting effective searches on Project Muse to find articles relevant to a class project, including how to frame a topic with keywords and synonyms, how to construct searches using Boolean operators and other tools, and how to evaluate results and cite sources properly. The objective is to guide students on searching Project Muse to locate useful information for their class projects and cite any information used.
This document summarizes the evolution of international society from ancient times to the modern era. It discusses key concepts like sovereign equality and non-intervention that form the basis of modern international society established by the Peace of Westphalia in 1648. The document then outlines how international society has globalized over time through decolonization, the end of the Cold War, and increasing challenges from globalization. It concludes by briefly introducing a case study on the Iranian Revolution of 1979.
Alfan P Laksono is a freelance design professional from Malang, Indonesia who currently lives in Bandung. He has worked in various design and teaching roles, including as a designer at APIC Enterprise Malang from 2008-2009, a lecturer assistant at Malang Joint Campus from 2008-2009, and currently serves as a lecturer at D4 ITB-SEAMOLEC and D1 ITB-SEAMOLEC. He also maintains professional portfolios on DeviantArt and YouTube and can be contacted via email.
Creative Partnerships commissioned Arts Inform to design, establish, manage and evaluate a two-phase mentoring programme pairing teachers in Creative Partnerships schools with representatives from cultural organizations. The evaluation of the second phase found that the 25 mentoring partnerships largely achieved their aims and objectives, which were highly relevant to the schools' work. Unexpected benefits included enhanced understanding between mentors and mentees as well as personal and professional growth for both parties. Evaluators emphasized the importance of structure, realistic expectations and school leadership support for partnership success.
This document describes night blinds that can save up to 41% on energy costs by keeping heat and cold air in refrigerated display cases when they are not operational. The blinds are made of a patented woven fabric that reflects heat and UV radiation, resists damage, and prevents condensation. They also have anti-bacterial coatings, strong magnets for easy installation, and printing options, and come in various standard and custom sizes to fit different display case types.
Customer Bulletin 0410 A Comparison of ISO-C1 and HT-300Joe Hughes
This Customer Bulletin is part of a series of white papers aimed at providing our clients, engineers, contractors, fabricators, and friends with objective information on competitive products. Marketing literature on the internet and in printed media address the physical and performance characteristics of competing polyisocyanurate rigid foam insulations fabricated from bunstock. As is often the case, some literature can be misleading and/or in some cases there may not be sufficient information to credibly compare products. This Customer Bulletin provides factual, clarifying information which should allow for an objective comparison of Dyplast’s ISO-C1® with HiTherm’s HT-300 (each 2 lb/ft3 density).
http://www.bridgewest.eu/company-formation-Iceland offers to You this presentation where You will discover all necessary information about how to open a company in Iceland.
The clients will benefit from the assistance of local lawyers.
http://www.bridgewest.eu is specialized in business formation in Europe and offshore jurisdictions.
Please contact us for more information at office@bridgewest.eu
GST implications on YouTuber Revenue.pptxtaxguruedu
Over the last three years, YouTube has paid its creators more than $50 billion dollars through the YouTube Partner Program. No doubt, the tax implication of such amount cannot be ignored.
This document provides an overview of key tax considerations related to mergers and acquisitions in India. It covers recent developments in India's tax laws including the introduction of taxation on virtual digital assets at 30%, extension of anti-avoidance rules against bonus stripping to new asset classes, and capping of the surcharge on long term capital gains at 15%. The document also discusses various forms of business entities in India, applicable tax rates, and clarifications issued on the interpretation of most favored nation clauses in India's tax treaties.
Start ups and MSMEs: Registration and Advantages features of Atmanirbhar packageNovojuris
Startups and MSMEs can register on relevant government portals to receive several benefits. Startups must register within 10 years of formation and have annual turnover less than Rs. 100 crore to qualify for benefits like income tax exemptions, self-certification under labour laws, stock options for founders. MSMEs must register based on investment and turnover limits set for micro, small and medium enterprises to prevent delayed payments and access collateral-free loans. The document outlines the registration processes and documents required for each as well as their key benefits.
This document discusses statutory compliances related to employee benefits in India. It provides details about the Gratuity Act 1972, including eligibility, calculation of gratuity, and rules. It also covers the Bonus Act 1965, including eligibility for bonus, calculation of bonus, and exemptions. Further, it explains the features of the Employees' Provident Fund including the different accounts, contribution rates, applicability, and eligibility.
The company meets its working capital requirements through commercial agreements with creditors and credit lines with banks. It manages cash efficiently and minimizes funds tied up in current assets. As of March 2010, the company had Rs. 77,298 million in cash, bank balances, and marketable securities. The company foresees liquidity needs for 3G and BWA spectrum auction fees and has adequately tied up funding. It also announced the acquisition of Zain Africa for USD 10.7 billion and has secured adequate funding for the deal. The company expects to maintain a comfortable liquidity position after paying spectrum fees and closing the acquisition.
The document outlines various laws and regulations that govern foreign investment and business operations in India, including the Foreign Exchange Management Act, Companies Act, tax laws, and others. It also summarizes different modes of foreign investment such as liaison offices, branch offices, joint ventures, technology transfers, and wholly-owned subsidiaries. For each investment type, it provides brief details on approval requirements, statutory compliances, taxation implications, and other considerations.
Dear Patron
Here we are with the Twenty Sixth successive issue of our monthly ‘Missive’.
We trust you will enjoy reading this Missive, even while soaking in the contents. We would very much appreciate your feedback which consistently helps us in improving and upgrading the contents.
Thanks and regards,
Knowledge Management Team
S.P.Nagrath & Co.
The document summarizes key proposed changes in the Income Tax Act 2023 in Bangladesh. Some of the major changes include:
- Reducing the number of tax return statements from 29 to 12 to simplify the return filing process.
- Providing a comprehensive list of deductible business expenses with new structures for general and specific deductions.
- Widening the caps on expense limits and including new areas for tax deductions to make the tax system more investment and business friendly.
- Introducing provisions to better align the tax laws with international financial reporting standards (IFRS) and address differences between IFRS and tax laws.
TDS and Income Tax Implications for Non-resident E-commerce OperatorsDVSResearchFoundatio
This document discusses tax and TDS implications for non-resident e-commerce operators in India. It provides background on India's taxation of the digital economy including the introduction of the concept of Significant Economic Presence (SEP) and Equalization Levy. SEP allows India to tax revenue generated from the Indian market for non-residents. Equalization Levy taxes online advertisement income and income from e-commerce supply or services by non-resident companies. The document also discusses TDS provisions introduced for payments made by e-commerce operators to e-commerce participants. It notes some open issues and caveats around SEP and Equalization Levy provisions. Finally, it provides an overview of OECD measures for taxation in the sharing
The document summarizes recent changes made to India's foreign direct investment policy across multiple sectors. Key changes include allowing 100% FDI in food trading through e-commerce, relaxing FDI limits and conditions in the defense, broadcasting, pharmaceuticals, aviation, and single-brand retail sectors. The changes aim to liberalize FDI rules and improve ease of business. Separate security clearances are no longer required for foreign company branches in certain sectors if they have government approvals. Most sectors will now be under the automatic approval route instead of requiring special permission. The reforms are expected to boost foreign investment, employment, and economic growth in India.
Significant FCRA Amendments: What they are and How they affect you !!Suhel Goel
The document summarizes significant amendments to the Foreign Contribution (Regulation) Act of 2010 in India. Key changes include making the registration, permission and renewal processes online through a single form. Documentation like applications and attachments must now be digitally filed. Payment is made through an online gateway and correspondence with the Ministry occurs through email. Annual returns must include audited financial statements and foreign-funded organizations must publicly disclose more details of contributions received. The amendments aim to modernize the process and increase transparency.
The Finance Bill 2014 introduces the concepts of "filers" and "non-filers" to distinguish between active and non-active taxpayers. A filer is defined as a taxpayer whose name appears on the active taxpayers list issued by the Federal Board of Revenue, or who has a taxpayer card. Significant differences are created between filers and non-filers under withholding tax provisions, with higher rates and amounts for non-filers in an effort to encourage more taxpayers to become filers and broaden the tax base.
TransPrice Times 15 December 2015 - 12 January 2016Sangesh Sase
Dear Readers,
Please find a link to the first edition of TransPrice Times for the new year 2016.
With the onset of holiday season, we saw some important judgement being pronounced by courts which are summarized in the alert.
Further, a long awaited guidance from the CBDT on the change in the residential status law which included the a global concept of 'Place of Effective Management' ('POEM') is also covered in the alert.
We hope you find this newsletter useful and look forward to your feedback and suggestions. You can write to us at akshaykenkre@transprice.in
Happy Reading!!!
TransPrice Times 15 December 2015 - 12 January 2016Akshay KENKRE
Dear Readers,
Please find a link to the first edition of TransPrice Times for the new year 2016.
With the onset of holiday season, we saw some important judgement being pronounced by courts which are summarized in the alert.
Further, a long awaited guidance from the CBDT on the change in the residential status law which included the a global concept of 'Place of Effective Management' ('POEM') is also covered in the alert.
We hope you find this newsletter useful and look forward to your feedback and suggestions. You can write to us at akshaykenkre@transprice.in
Happy Reading!!!
PAMS Professional Group Monthly NewsLetter -MAY 2020PAMS
Greetings from PAMS Professional Group
Hi friends we all are stranded with the extended lockdown and most of us feeling the pressure of what could happen? To our industry? To our employment? To our finances? Or our fortunes so to speak? When the going gets tough let the tough get going. There is always a bright day after a storm . As we all work from home with social distance please remain updated with what occurs around. We present our monthly newsletter. Hope you will find them useful.
www.ppginternational.com
Dear Patron,
Here we are with the Thirty forth successive issue of our monthly ‘Missive’.
We trust you will enjoy reading this Missive, even while soaking in the contents. We would very much appreciate your feedback which consistently helps us in improving and upgrading the contents.
Thanks and regards,
Knowledge Management Team
This document provides an overview of direct tax implications in India for companies looking to do business in the country. It discusses key aspects like the scope of taxable income for resident and non-resident companies, applicable corporate tax rates, considerations around dividend income, minimum alternate tax, and other tax obligations. The document also covers indirect tax implications and specifics of the taxation system relevant for non-resident entities operating in India.
The document summarizes the presentation on overseas direct investment given by Mr. Paresh P. Shah. It discusses the history and rationale for outbound investment from India. It provides an overview of the automatic route and approval route for overseas investments, including eligible investors, investment limits, reporting requirements, and post-approval compliance. It also outlines various factors that affect decisions around overseas investments, including general economic and corporate considerations as well as tax implications.
Newsletter on daily professional updates- 14/07/2020CA PRADEEP GOYAL
This newsletter provides updates across various professional fields including direct tax, indirect tax, accounting, insolvency and bankruptcy, and the economy. It covers notifications, circulars, legal updates, and reports from organizations like CBDT, CBIC, ICAI, ICSI, IBBI, SEBI, and RBI. The newsletter is published daily from Monday to Friday by Pradeep Goyal, who is a chartered accountant and insolvency professional. It aims to keep readers informed of all relevant regulatory changes and developments in one document.
The APCO Geopolitical Radar - Q3 2024 The Global Operating Environment for Bu...APCO
The Radar reflects input from APCO’s teams located around the world. It distils a host of interconnected events and trends into insights to inform operational and strategic decisions. Issues covered in this edition include:
Prescriptive analytics BA4206 Anna University PPTFreelance
Business analysis - Prescriptive analytics Introduction to Prescriptive analytics
Prescriptive Modeling
Non Linear Optimization
Demonstrating Business Performance Improvement
IMPACT Silver is a pure silver zinc producer with over $260 million in revenue since 2008 and a large 100% owned 210km Mexico land package - 2024 catalysts includes new 14% grade zinc Plomosas mine and 20,000m of fully funded exploration drilling.
Ellen Burstyn: From Detroit Dreamer to Hollywood Legend | CIO Women MagazineCIOWomenMagazine
In this article, we will dive into the extraordinary life of Ellen Burstyn, where the curtains rise on a story that's far more attractive than any script.
Best Competitive Marble Pricing in Dubai - ☎ 9928909666Stone Art Hub
Stone Art Hub offers the best competitive Marble Pricing in Dubai, ensuring affordability without compromising quality. With a wide range of exquisite marble options to choose from, you can enhance your spaces with elegance and sophistication. For inquiries or orders, contact us at ☎ 9928909666. Experience luxury at unbeatable prices.
During the budget session of 2024-25, the finance minister, Nirmala Sitharaman, introduced the “solar Rooftop scheme,” also known as “PM Surya Ghar Muft Bijli Yojana.” It is a subsidy offered to those who wish to put up solar panels in their homes using domestic power systems. Additionally, adopting photovoltaic technology at home allows you to lower your monthly electricity expenses. Today in this blog we will talk all about what is the PM Surya Ghar Muft Bijli Yojana. How does it work? Who is eligible for this yojana and all the other things related to this scheme?
Cover Story - China's Investment Leader - Dr. Alyce SUmsthrill
In World Expo 2010 Shanghai – the most visited Expo in the World History
https://www.britannica.com/event/Expo-Shanghai-2010
China’s official organizer of the Expo, CCPIT (China Council for the Promotion of International Trade https://en.ccpit.org/) has chosen Dr. Alyce Su as the Cover Person with Cover Story, in the Expo’s official magazine distributed throughout the Expo, showcasing China’s New Generation of Leaders to the World.
The Genesis of BriansClub.cm Famous Dark WEb PlatformSabaaSudozai
BriansClub.cm, a famous platform on the dark web, has become one of the most infamous carding marketplaces, specializing in the sale of stolen credit card data.
Discover timeless style with the 2022 Vintage Roman Numerals Men's Ring. Crafted from premium stainless steel, this 6mm wide ring embodies elegance and durability. Perfect as a gift, it seamlessly blends classic Roman numeral detailing with modern sophistication, making it an ideal accessory for any occasion.
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2. abm & associates
CHARTERED ACCOUNTANTS
Head Office : Navi Mumbai Branches : Pune | Kolhapur | Belgaum 1
Contents
WEB SEARCH ONLINE ADVERTISEMENT PAYMENTS MADE TO GOOGLE AND YAHOO NOT
TAXABLE IN INDIA______________________________________________________ 2
IN BRIEF ...................................................................................................................................2
ISSUE UNDER CONSIDERATION ........................................................................................................3
TRIBUNAL RULING........................................................................................................................3
OUR VIEW .................................................................................................................................3
CHANGES IN THE CONSOLIDATED FDI POLICY GUIDELINES EFFECTIVE FROM APRIL 25,
2013_________________________________________________________________ 4
TAX DEDUCTION AT SOURCE (TDS) RATES FOR FY 2013-14 ______________________ 6
UNINTERRUPTED POWER SUPPLY (“UPS”) IS ENERGY SAVING DEVICE AND HENCE
QUALIFIES FOR 80% DEPRECIATION _______________________________________ 8
IN BRIEF ...................................................................................................................................8
ISSUE UNDER CONSIDERATION: .......................................................................................................8
TRIBUNAL RULING: ......................................................................................................................8
TRIBUNAL HELD THAT ...................................................................................................................8
SERVICE TAX RETURN FILING DATE FOR OCT-2012 TO MARCH-2013 EXTENDED TO
31.08.2013____________________________________________________________ 9
3. abm & associates
CHARTERED ACCOUNTANTS
Head Office : Navi Mumbai Branches : Pune | Kolhapur | Belgaum 2
Web Search Online Advertisement Payments made to Google and Yahoo
not taxable in India
In Brief
Recently, ITAT Kolkata ‘B’ Bench in case of
Right Florists Pvt. Ltd1
held that payment
made to Google and Yahoo for Online Web
Search engine based advertisement is not
liable to be tax in India as “Website”
doesn’t constitute ‘PE’ unless the servers
on which websites are hosted are also
located in the same jurisdiction. As the
servers of Google and Yahoo are not
located in India, there is no PE in India.
Further, it has also held that payment is
neither “Royalty” u/s 9(1)(vi) nor “FTS” u/s
9(1)(vii).
Facts
Assessee is a florist and he uses advertising
1 I.T.A. No.: 1336/ Kol. / 2011 for A.Y. 2005-06
on search engines, i.e. by Google and
Yahoo, which does a web search for anyone
on use of certain keywords whereby
assessee name is shown as a result of such
search. The assessee had made payments
aggregating to Rs 30.44 Lakhs in respect of
online advertising to US based entities,
namely Google Ireland Limited (Google
Ireland, in short) and Overture Services Inc
USA (Yahoo USA, in short). However, no
taxes were withheld from these payments.
The AO held that the assessee ought to
have deducted TDS and that as there was
a failure, the expenditure was not allowable
u/s 40(a)(i). This was deleted by the CIT
(A) on the ground that Google and Yahoo
did not have a PE in India.
4. abm & associates
CHARTERED ACCOUNTANTS
Head Office : Navi Mumbai Branches : Pune | Kolhapur | Belgaum 3
Issue under consideration
Whether payment made to Google and
Yahoo for Online Web Search based
Advertisement Payment is taxable in India
either as “Business Income”, or as
“Royalty” or as “FTS”.
Tribunal Ruling
Tribunal held that
A website does not constitute a
‘permanent establishment’ unless the
servers on which websites are hosted
are also located in the same jurisdiction.
As the servers of Google and Yahoo are
not located in India, there is no PE in
India. S. 9(1)(i) does not apply as there
is no “business connection” in India nor
are the online advertising revenues
generated in India.
As regards s. 9(1)(vi), relying on
decision in case Yahoo2
and Pinstorm3
that the advertising revenues are not
assessable as “royalty”.
As regards ‘FTS” under s. 9(1)(vii), the
services are not “managerial” or
“consultancy” in nature as both these
2 140 TTJ 195 (Mum)
words involve a human element.
Applying the rule of noscitur a sociis,
even the word “technical” in
Explanation 2 to s. 9 (1) (vii) would
have to be construed as involving a
human element. If there is no human
intervention in a technical service, it
cannot be treated as a technical service
u/s 9(1)(vii). The process is a wholly
automated as services are rendered by
the search engines, there is no human
touch at all. The results are completely
automated. Consequently, the whole
process of actual advertising service
provided by Google & Yahoo, even if it
be a technical service, is not covered by
the limited scope of s. 9(1)(vii).
Consequently, the receipts in respect of
online advertising on Google and Yahoo
cannot be brought to tax in India under the
provisions of the Act or the India US and
India Ireland tax treaty.
Our View
This verdict has reasserted that mere
‘Website’ doesn’t constitute “Permanent
Establishment” and wholly automated
process without human intervention
doesn’t amount to ‘Technical Service’
3 54 SOT 78 (Mum)
5. abm & associates
CHARTERED ACCOUNTANTS
Head Office : Navi Mumbai Branches : Pune | Kolhapur | Belgaum 4
Changes in the Consolidated FDI Policy Guidelines effective from April
25, 2013
Pricing of shares
The criteria has been changed for the
shares subscribed under Memorandum
of Association. Now the condition of
DFCF method in case of subscription
shares has been dispensed with and
such shares can be issued at face value.
Conversion of External Commercial
Borrowings / Lump Sum Fee /
Royalty etc. into Equity
As per old FDI Policy, the companies
were allowed to issue Equity Shares
against import of capital goods /
machinery (excluding second hand
machinery), subject to certain
conditions. One among these conditions
was mandatory requirement of
independent valuation of Capital goods
/ machinery by third party, preferably
by an independent valuer from the
country of import along with production
of copies of documents issued by
customs authorities towards
assessment of the fair value of such
imports. The said condition is dispensed
with in new FDI Policy dated April 5,
2013.
Pakistan citizens, nationals and
companies are allowed to invest in India
after prior approval from the
government.
RBI has prescribed the format for filing
annual Return of Foreign Assets &
Liabilities for Indian Companies. The
said return is to be filed with RBI.
Transfer of Shares / Convertible
debentures from Resident to Non –
Resident
As per amended definition of ‘Person
Resident Outside India’ includes foreign
national, NRI, incorporated non-
resident entities, FII other than
erstwhile OCBs. Earlier definition of
‘Person Resident Outside India’
excluded foreign national, FII, NRI for
6. abm & associates
CHARTERED ACCOUNTANTS
Head Office : Navi Mumbai Branches : Pune | Kolhapur | Belgaum 5
the purposes of transfer of Shares /
Convertible Debentures from resident
to non-resident.
Allowed 49% stake by a foreign airlines
in the domestic carriers which are cash-
strapped.
Raised FDI cap in various broadcasting
services to 74%.
Allowed upto 51% inflows of FDI in
multi-brand retail sector.
Permitted up to 49% foreign investment
in the power trading exchanges.
Increased foreign investment ceiling in
ARCs to 74%, up from 49%. This move
is aimed at inviting foreign expertise in
this segment. It has also been said that
the total shareholding of an FII in an
ARC will not exceed 10 per cent of the
total paid-up capital.
7. abm & associates
CHARTERED ACCOUNTANTS
Head Office : Navi Mumbai Branches : Pune | Kolhapur | Belgaum 6
TAX DEDUCTION AT SOURCE (TDS) RATES FOR FY 2013-14
Sr.
No.
Section
of
Income
Tax Act
Nature of Payment to Resident
Threshold
Limit
₹
Rates in force4
(%)
Individual
or HUF
Others
1 192 Salaries (including payments to Non-Resident)
Basic
Exemption
Slab
Rates5 -
2 193 Interest on Securities 5,000 10 10
3 194 Deemed dividend - 10 10
4 194A
Interest other than Interest on Securities by
Bank on Term Deposit
10,000 10 10
5 194A Interest other than Interest on Securities 5,000 10 10
6 194B Lottery, Cross Word Puzzle, Gambling 10,000 30 30
7 194BB Winnings from Horse Race 5,000 30 30
8 194C
Contracts including Sub-Contracts,
Advertisement Contracts6 30,0007
1 2
9 194D Insurance Commission 20,000 10 10
10 194EE Payments out of deposits under NSS 2,500 20 -
11 194F Repurchase of units by MF/UTI 1,000 20 20
12 194G Commission on sale of lottery tickets 1,000 10 10
13 194H Commission or Brokerage 5,000 10 10
14 194I
Rent for Land, building, furniture or fittings 1,80,000 10 10
Rent for Plant and Machinery, Equipment,
Vehicles etc.
1,80,000 2 2
15 194IA
Transfer of immovable property other than
agriculture land8 50 Lakh 1 1
16 194J
Fees for Professional, Technical Services or
Royalty or Non-compete
30,000 10 10
Any remuneration or fees or commission paid to
director of the company including Sitting Fees
other than Salaries9
NIL 10 10
17 194LA
Compensation on acquisition of immovable
property
2,00,000 10 10
4 Rate shall be at “rates in force” or 20% whichever is higher in case payee doesn’t possess PAN
5 Equal Monthly Instalment of Estimated Yearly Tax (Tax including Surcharge and cess applicable)
6 No TDS on payment of freight for Goods Transport to Transport contractor furnishing PAN to payer
7 Individual Contract less than ₹ 30,000 but aggregate of all contracts during the year exceeds ₹ 75,000- TDS applicable.
8 Newly inserted by Finance Bill, 2013, shall be effective from 1.06.13, Purchaser shall deduct the Tax.
9 Effective from 1.07.12
8. abm & associates
CHARTERED ACCOUNTANTS
Head Office : Navi Mumbai Branches : Pune | Kolhapur | Belgaum 7
Note:
a) TDS needs to be deducted on payment or credit whichever is earlier including credit to
“Suspense Account”.
b) TDS needs to be paid with 7 days from date of deduction in case of salaries and before
7th of the succeeding month in case of payments other than salaries. TDS deducted on
31st March (on Credit) shall be paid before 30th of April.
c) Quarterly Return in Form 24 in case of Salary and in Form 26 in case of others before
15th of the end of Quarter and before 15th of May in case of March Quarter needs to
filed.
d) Non-deduction, delay deduction, wrong deduction are liable for interest @ 1.5% per
Month and delay in payment is liable for interest @1 % per month.
e) Non-deduction, Non-payment of Tax before due date of filing Return of Income is liable
for disallowance of Expenditure and penalties and prosecutions (in case delay is beyond
1 year) and Deductor shall be treated as “Assessee in Default”
f) Delay in filing Quarterly Returns is liable for fees of ₹ 200 per day of delay (mandatorily)
in addition to Penalty.
9. abm & associates
CHARTERED ACCOUNTANTS
Head Office : Navi Mumbai Branches : Pune | Kolhapur | Belgaum 8
Uninterrupted Power Supply (“UPS”) is Energy Saving Device and hence
qualifies for 80% Depreciation
In Brief
Recently, ITAT Mumbai ‘G’ Bench in case of
Godery Phillips India Ltd10
held that
Uninterrupted Power Supply (“UPS”) is an
‘Automatic Voltage Controller’ falling within
the heading ‘Energy Saving Device‘in the
Appendix to the Income Tax Rules 1962
giving depreciation rates @ 80% and hence
qualifies for such depreciation.
Facts:
Assessee for the Assessment Year 2006-07
and 2007-08 considering the Uninterrupted
Power Supply (“UPS”) as Energy Saving
Device had claimed depreciation at higher
rate i.e. 80%. AO disallowed such excess
depreciation of ₹ 5,74,579 for A.Y. 2006-07
and ₹ 4,72,596 for A.Y. 2007-08.
Issue under consideration:
Whether Uninterrupted Power Supply
(“UPS”) is an ‘Automatic Voltage Controller’
falling within the heading ‘Energy Saving
Device‘ and eligible for higher Depreciation.
Tribunal Ruling:
Tribunal held that
“Automatic Voltage Controller’ falling
within the heading of energy saving device
10 ITA No. 7682/Mum/2010 and ITA No. 8549/Mum/2010
in the Appendix to the Income Tax Rules
1962 giving depreciation rates. Legislature
in its wisdom has chosen to show an
Automatic Voltage Controller’ as an
electrical equipment eligible for 100%
depreciation, falling under the broader
head of energy saving devices. Once
Legislature deemed that an ‘Automatic
Voltage Controller’ is a specie falling within
energy saving device, it is not for the
Assessing Officer or Ld. CIT (A) to further
analyse whether such an Item would
indeed an energy saving device. In fact it
is beyond their powers. Hence the only
question to answer, in our opinion is
whether an UPS is an Automatic Voltage
Controller’. It is mentioned in the product
that the UPS automatically corrected low
and high voltage conditions and stepped up
low voltage to safe output levels. Thus in
our opinion there cannot be a quarrel that
UPS was doing the job of voltage
controlling automatically. Even when it was
supplying electricity at the time of power
voltage, the outages remained controlled.
Therefore in our opinion a UPS would
definitely fall under the head of ‘Automatic
Voltage Controller’.
10. abm & associates
CHARTERED ACCOUNTANTS
Head Office : Navi Mumbai Branches : Pune | Kolhapur | Belgaum 9
Service Tax Return Filing date for Oct-2012 to March-2013 Extended
to 31.08.2013
Date for filing the ST-3 return, for the
period from Oct’12 to March’13 has been
extended from 25th Apr, 2013 to 31st
August, 2013
Vide Order No: 03/2013-Service
Tax, CBEC has extended the return filing
date for the period starting October, 2012
to March, 2013, from 25th April, 2013 to
31st August, 2013. Further it is also
informed that utility to prepare the service
tax return will be available at ACES website
by 31st July, 2013.
Please refer Notification No: Order No:
03/2013-Service Tax dated 23rd
April, 2013
at
https://www.aces.gov.in/Documents/orde
r_3_of_2013_service_tax_dated_23_4_20
13.pdf
11. abm & associates
CHARTERED ACCOUNTANTS
Head Office : Navi Mumbai Branches : Pune | Kolhapur | Belgaum 10
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