The Covid-19 pandemic has
dramatically disrupted business operations and financial markets, leaving many
companies scrambling to adjust to ever-changing economic circumstances. Many
companies are still managing business emergencies or reorganizing operations on
the fly, but as organizations begin to stabilize and plan for 2021 (and
beyond), transfer pricing is one area that companies should be thinking about.
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This is the form for providing information to be furnished under Sub-section (6) of Section 195 of Income Tax Act, 1961 relating to remittance of payments to a non-resident or to a foreign company |
Income tax implications for Employees who have been granted shares under Employee Stock Options Scheme (ESOP's) and this is mostly at a per-share price which is significantly lower compared to the prevailing price at which the company share is traded.
One may wonder that Black Money Act is for people having black money in Foreign banks and not for the common taxpayer. But beware of such a notion! One may get sleepless nights and may get hound with notices under Black Money Act for mere forgetting to disclose the details of foreign assets and bank accounts in their Income Tax Returns (ITR) which might be the simple clerical error of you or your tax advisor while filing ITR.
When it comes to securing generational wealth and our children’s future, there is nothing more important than succession and estate planning. At its heart, estate planning is the simple act of preparing for the transfer of a person’s wealth and assets during and/or after their death. One of the most important tools in estate planning is a Family Trust (“Trust”). While Wills are hygiene documents put in place to take care of inheritances in a simpler manner, they have their own set of limitations:
In the recent Circular No. 23/2021-Customs dated September 30, 2021, wherein the Central Board of Indirect Taxes and Customs (‘CBIC’) has specified the mechanism for issuance of e-scrips under RoDTEP scheme.
Income Tax Department is introducing a completely new
reengineered Form 15CA and Form 15CB submission process based on various
feedbacks provided by numerous corporates and professionals all over India.
These transformations will simplify the preparation, assignment, submission,
and verification process involved in the entire filing cycle of the Form.
In a major relief to JMW India, the Income Tax Appellate Tribunal (ITAT), Delhi bench has held that the interest subsidy and the excise duty refund shall be treated as capital receipts and therefore, not subject to income tax while computing book profit under the provisions of the Income Tax Act, 1961. Theassessee, a company engaged in the business of trading and manufacturing of copper products, filed its income tax return declaring total income at Rs.1,23,71,780/-. The Assessing Officer, while completing the proceedings, observed thatthe assessee, had received an amount of Rs.30,01,143/- representing interest subsidy and an amount of Rs.4,98,49,144/- representing Excise Duty refund which are subject to income tax. Before ethe Tribunal, the assessee contended that the interest subsidy of Rs.30,01,143/- and Excise Duty refund of Rs.4,98,49,144/- shall be excluded for the purpose of computing book profit u/s 115JB. While allowing the plea of the assessee, Judicial Member Vijay Pal Rao and Accountant Member R K Panda held that “since, in the instant case, the Revenue has accepted the order of the CIT(A) in holding that interest subsidy and Excise Duty refund are capital receipts, therefore, respectfully following the decision of the Hon’ble Calcutta High Court in the case of Ankit Metal & Power Ltd., cited (supra) and in absence of any contrary material brought to our notice, we hold that the above two receipts being not in the nature of income cannot be included for the purpose of computation u/s 115JB of the IT Act. We, therefore, set aside the order of the ld.CIT(A) on this issue and allow the grounds raised by the assessee.”
Facts:
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Company A registered in India providing software services to its global
customers.
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To serve its Global customers, Company A
opened foreign branches in different parts of the world.
· These overseas branches provide onsite service and sales & marketing services to the clients of the Company A. For these onsite services rendered by the branches, the concerned branch of the Company A would raise the invoice directly on the clients/customers. However, the amounts are collected or received directly into the Indian banks of the Company A. The Company A would transfer funds to its overseas branches to meet the expenses of the respective branch
A “safe harbor” is defined in the Indian Income Tax Law (ITL) as circumstances under which the tax authorities will accept the transfer price declared by the taxpayer. India’s Central Board of Direct Taxes (CBDT), the apex Indian tax administration body, first issued transfer pricing (TP) safe harbor rules (SHR) on 18 September 2013, applicable for five years from financial year (FY) 2012-13 to FY 2016-17. The CBDT through notification dated 7 June 2017 amended the SHR, which were applicable for three FYs from FY 2016-17 through FY 2018-19. For FY 2016-17, taxpayers had the option to elect the rule which was more beneficial. On 20 May 2020, the CBDT issued a notification amending the SHR to extend the applicability to FY 2019-20, without any modifications.
The note discusses few aspects to be checked by the Buyer of
Immovable property. We will focus on the purchase of Flat
or Office space
or Land (Non-Agricultural)
