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Model Commentary
As Amended by Finance Act 2017
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FEATURES OF THE TRANSFER PRICING REGIME UNDER CHAPTER X
FEATURES OF THE TRANSFER PRICING REGIME UNDER CHAPTER X 2.1 Features of the ...
TRANSFER PRICING PROVISIONS OF CHAPTER X - WHEN APPLICABLE TO AN ASSESSEE
TRANSFER PRICING PROVISIONS OF CHAPTER X - WHEN APPLICABLE TO AN ASSESSEE 3.0 ...
WHO ARE “ASSOCIATED ENTERPRISES” (AEs)?
WHO ARE "ASSOCIATED ENTERPRISES" (AEs)? 4.0 Mere mention in Form No. 3CEB of ...
WHAT IS “INTERNATIONAL TRANSACTION”?
WHAT IS "INTERNATIONAL TRANSACTION"? To invoke Chapter X, burden on Revenue is ...
INTERNATIONAL TRANSACTIONS : PURCHASE, SALE OR LEASE OF TANGIBLE PROPERTY
INTERNATIONAL TRANSACTIONS : PURCHASE, SALE OR LEASE OF TANGIBLE PROPERTY 6.1 ...
INTERNATIONAL TRANSACTIONS : INTANGIBLE PROPERTY TRANSACTIONS
INTERNATIONAL TRANSACTIONS : INTANGIBLE PROPERTY TRANSACTIONS 7.1 Intangible ...
INTERNATIONAL TRANSACTIONS : BORROWING OR LENDING OF MONEY/ FINANCING
INTERNATIONAL TRANSACTIONS : BORROWING OR LENDING OF MONEY/ FINANCING 8.1 ...
INTERNATIONAL TRANSACTIONS : PROVISION OF SERVICES
INTERNATIONAL TRANSACTIONS : PROVISION OF SERVICES 9.1 Definition of provision ...
INTERNATIONAL TRANSACTIONS : COST CONTRIBUTION AGREEMENTS
INTERNATIONAL TRANSACTIONS : COST CONTRIBUTION AGREEMENTS 10.1 Cost ...
BUSINESS RESTRUCTURING OR ORGANISATION
BUSINESS RESTRUCTURING OR ORGANISATION 11.1 Transaction of business ...
DEFINITION OF SPECIFIED DOMESTIC TRANSACTIONS
DEFINITION OF SPECIFIED DOMESTIC TRANSACTIONS 12.1 Definition of specified ...
EFFECT OF APPLICABILITY OF TRANSFER PRICING PROVISIONS
DIVISION TWO COMPUTATION OF ARM's LENGTH PRICE EFFECT OF APPLICABILITY OF ...
WHAT IS ARM’s LENGTH PRICE
WHAT IS ARM's LENGTH PRICE 14.0 Rebuttable presumption that international ...
HOW TO COMPUTE ARM’S LENGTH PRICE
HOW TO COMPUTE ARM's LENGTH PRICE 15.1 Methods for determination of ALP ...
BENCHMARKING : COMPARABILITY ANALYSIS & COMPARABLES
BENCHMARKING : COMPARABILITY ANALYSIS COMPARABLES 16.0 Comparison with ...
WHAT IS COMPARABLE UNCONTROLLABLE PRICE (CUP) METHOD AND HOW TO APPLY IT TO CALCULATE ALP?
WHAT IS COMPARABLE UNCONTROLLABLE PRICE (CUP) METHOD AND HOW TO APPLY IT TO ...
WHAT IS RESALE PRICE METHOD (RPM) AND HOW TO APPLY IT TO CALCULATE ALP?
WHAT IS RESALE PRICE METHOD (RPM ) AND HOW TO APPLY IT TO CALCULATE ALP? 18.1 ...
WHAT IS COST PLUS METHOD (CPM ) AND HOW TO APPLY IT TO CALCULATE ALP?
WHAT IS COST PLUS METHOD (CPM ) AND HOW TO APPLY IT TO CALCULATE ALP? 19.1 Cost ...
WHAT IS PROFIT SPLIT METHOD (PSM) AND HOW TO APPLY IT TO CALCULATE ALP?
WHAT IS PROFIT SPLIT METHOD (PSM) AND HOW TO APPLY IT TO CALCULATE ALP? When ...
WHAT IS TRANSACTIONAL NET MARGIN METHOD (TNMM) AND HOW TO APPLY IT TO CALCULATE ALP?
WHAT IS TRANSACTIONAL NET MARGIN METHOD (TNMM) AND HOW TO APPLY IT TO CALCULATE ...
ANY OTHER METHOD - RULE 10AB
ANY OTHER METHOD - RULE 10AB 22.1 Rule 10AB is retrospective and effective from ...
MOST APPROPRIATE METHOD (MAM)
MOST APPROPRIATE METHOD (MAM) 23.1 Selection of MAM-factors to be taken into ...
INTERNATIONAL TRANSACTIONS : DETERMINATION OF ALP FOR IMPORT OF GOODS
INTERNATIONAL TRANSACTIONS: DETERMINATION OF ALP FOR IMPORT OF GOODS 24.1 ...
INTERNATIONAL TRANSACTIONS : DETERMINATION OF ALP FOR INTEREST FREE LOAN TO AEs
INTERNATIONAL TRANSACTIONS : DETERMINATION OF ALP FOR INTEREST FREE LOAN TO AEs ...
INTERNATIONAL TRANSACTIONS INVOLVING INTANGIBLES : DETERMINATION OF ALP
INTERNATIONAL TRAN-SACTIONS INVOLVING INTANGIBLES : DETERMINATION OF ALP 26.1 ...
INTERNATIONAL TRANSACTIONS : WHEN DEVELOPMENT CENTRES IN INDIA CAN BE TREATED AS CONTRACT R&D SERVICE PROVIDER WITH INSIGNIFICANT RISK
INTERNATIONAL TRANSACTIONS : WHEN DEVELOPMENT CENTRES IN INDIA CAN BE TREATED ...
INTERNATIONAL TRANSACTIONS : DETERMINATION OF ALP FOR INDENTING ACTIVITY
INTERNATIONAL TRANSACTIONS : DETERMINATION OF ALP FOR INDENTING ACTIVITY 28.1 ...
TRANSFER PRICING ADJUSTMENTS
DIVISION THREE TP ADJUSTMENTS AND THIN CAP ADJUSTMENTS TRANSFER PRICING ...
THIN CAPITALIZATION ADJUSTMENTS
THIN CAPITALIZATION ADJUSTMENTS 30.1 Concepts of "Thin capitalization" and ...
SECONDARY ADJUSTMENTS
SECONDARY ADJUSTMENTS 31.1 Secondary adjustments - Concept "Secondary ...
POWER OF AO TO COMPUTE ALP
DIVISION FOUR TRANSFER PRICING PROCEDURES POWER OF AO TO COMPUTE ALP 32.1 Power ...
REFERENCE TO TRANSFER PRICING OFFICER - SECTION 92CA
REFERENCE TO TRANSFER PRICING OFFICER - SECTION 92CA 33.1 Power of AO to make a ...
TRANSFER PRICING DISPUTE RESOLUTION MECHANISM
TRANSFER PRICING DISPUTE RESOLUTION MECHANISM 34.1 Dispute resolution mechanism ...
SAFE HARBOUR RULES - SECTION 92CB
SAFE HARBOUR RULES* 35.1 "Safe harbour rules" - Concept "Safe Harbour" means ...
ADVANCE PRICING AGREEMENT - SECTIONS 92CC AND 92CD
ADVANCE PRICING AGREEMENT * 36.1 Advance Pricing Agreement ("APA") - Concept ...
OBLIGATION OF ASSESSEES TO MAINTAIN TRANSFER PRICING DOCUMENTATION - SECTION 92D
OBLIGATION OF ASSESSEES TO MAINTAIN TRANSFER PRICING DOCUMENTATION* 37.1 ...
AUDIT REPORT
AUDIT REPORT* 38.1 Obligation of assessee entering into international ...
AUDIT REPORT & DOCUMENTATION – INTERNATIONAL TRANSACTIONS
DIVISION FIVE TRANSFER PRICING AUDIT AUDIT REPORT DOCUMENTATION INTERNATIONAL ...
AUDIT REPORT & DOCUMENTATION – SPECIFIED DOMESTIC TRANSACTIONS
AUDIT REPORT DOCUMENTATION - SPECIFIED DOMESTIC TRANSACTIONS 40.1 Para 1 of ...
DUE DATE FOR FILING RETURN FOR ASSESSEES REQUIRED TO FURNISH AUDIT REPORT U/S 92E - SECTION 139
DUE DATE FOR FILING RETURN FOR ASSESSEES REQUIRED TO FURNISH AUDIT REPORT U/S ...
TIME LIMITS FOR ASSESSMENT AND REASSESSMENT - SECTIONS 153 AND 153B
TIME LIMITS FOR ASSESSMENT AND REASSESSMENT - SECTIONS 153 AND 153B 42.1 ...
PENALTY - SECTIONS 271, 271AA, 271BA AND 271G
PENALTY - SECTIONS 271, 271AA, 271BA AND 271G 43.1 Penalty for concealment - ...
INTRODUCTION
AS AMENDED BY FINANCE ACT, 2013 INTRODUCTION 1.0 Expressions "Transfer Price" ...