Friday, 31 August 2012

CBDT Releases Transfer Pricing “Advance Pricing Agreement Scheme” (“APA”)

Vide Notification No. 36 of 2012 dated 30.08.2012, the CBDT has inserted Rules 10F to 10T to introduce the “Advance Pricing Agreement Scheme”.

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No Permanent Establishment Unless Proven by the Revenue

The Income Tax Appellate Tribunal (Delhi Bench) recently in the case of SAIC clarified an important principle in international taxation: th...