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Dear Subscriber,
Transfer Pricing: Most Appropriate Method For Computing Arm's Length Price (ALP) Of An International Transaction
Advocate P. C. Yadav has explained the concept of "Most Appropriate Method" as referred to in section 92C of the Income-tax Act, 1961 read with Rule 10C of the Income-tax Rules. He has collated all the important judgements on the subject and pointed out the various factors that a taxpayer has to take into account while choosing one of the several methods to benchmark his international transaction and prove that it is at arm's length See Also: Digest of case laws (updated regularly) containing latest judgements reported in BCAJ, CTR, DTR, ITD, ITR, ITR (Trib), Chamber's Journal, SOT, Taxman, TTJ, BCAJ, ACAJ, www.itatonline.org and other journals
Withering Of Tribunal's Stay Granting Powers – When Does The Hammer Drop?
Advocate Sukhsagar Syal has formulated the proposition that every assessee has a vested right to file an appeal and to obtain a stay of demand and that this right cannot be taken away by an amendment to the Act. He has argued that consequently the amendment to section 254 of the Income-tax Act (which takes away the Tribunal's absolute power to grant stay) will apply only to those cases where the assessment order is passed on or after 1st April, 2020. In all other cases, the Tribunal will continue to hold the power of granting stay of demand without any restriction. He has supported his proposition with an extensive reference to several case laws__._,_.___
Posted by: "editor@itatonline.org" <itatonline.org@gmail.com>
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