Latest Expert Exchange Queries

GST Demo Service software link: https://ims.go2customer.com
Username: demouser Password: demopass
Get your inventory and invoicing software GST Ready from Binarysoft info@binarysoft.com
sitemapHome | Registration | Job Portal for CA's | Expert Exchange | Currency Converter | Post Matrimonial Ads | Post Property Ads
 
 
News shortcuts: From the Courts | News Headlines | VAT (Value Added Tax) | Placements & Empanelment | Various Acts & Rules | Latest Circulars | New Forms | Forex | Auditing | Direct Tax | Customs and Excise | ICAI | Corporate Law | Markets | Students | General | Mergers and Acquisitions | Continuing Prof. Edu. | Budget Extravaganza | Transfer Pricing | GST - Goods and Services Tax
 
 
 
 
Popular Search: cpt :: articles on VAT and GST in India :: ACCOUNTING STANDARD :: Central Excise rule to resale the machines to a new company :: TAX RATES - GOODS TAXABLE @ 4% :: list of goods taxed at 4% :: form 3cd :: VAT Audit :: VAT RATES :: ARTICLES ON INPUT TAX CREDIT IN VAT :: empanelment :: TDS :: ACCOUNTING STANDARDS :: ICAI offer Get Windows 7,Office 2010 in Rs.799 Taxes :: due date for vat payment
 
 
ITAT-Constitution of Benches »
 Income Tax Appellate Tribunal Pune Benches Cause List for Bench "B"for the week ending 19/01/2018
 Income Tax Appellate Tribunal Mumbai Benches Mumbai Constitution of Benches for the Period from 22/01/2018 To 25/01/2018
 Income Tax Appellate Tribunal, Visakhapatnam Bench During The Period From 15.01.2018 To 26.01.2018
 Income Tax Appellate Tribunal, Hyderabad Benches, Hyderabad. Cause List Of Cases Posted Before B-Bench (DB) - 15.01.18 To 19.01.18
 Income Tax Appellate Tribunal, Pune Benches, Pune. Cause List Bench "B" for the week ending 19.01.2018
 Income Tax Appellate Tribunal, Hyderabad Benches, Hyderabad. Cause List Of Cases Posted Before A-Bench (DB ) - 15.01.2018 To 19.01.2018
 Income Tax Appellate Tribunal : Kolkata Benches : Kolkata Consolidated List Of Orders Ready For Pronouncement On 12/01/2018.
 Income Tax Appellate Tribunal Mumbai Benches Mumbai Consolidated Cause list of SA/MA?Pronouncement for Friday 12/01/2018
 Income Tax Appellate Tribunal, Bangalore Benches, Bangalore Couselist for the week from 08/01/2018 To 11/01/2018
 Income Tax Appellate Tribunal, Ahmedabad Benches, Ahmedabad Constitution For The Period From 15-01-2018 To 18-01-2018 & 22-01-2018 To 25-01-2018
 Income Tax Appellate Tribunal Mumbai Benches Mumbai Consolidated list of orders ready for Pronouncement on 10/01/2018

Vijai Electricals Ltd vs. ACIT (ITAT Hyderabad)
June, 05th 2013

Transfer pricing provisions do not apply (i) to an investment in share capital of overseas companies & (ii) to transactions where no “income” has arisen

The assessee invested Rs. 21 crores in the share capital of its overseas subsidiaries. The AO completed the assessment without making any transfer pricing adjustment. The CIT revised the assessment u/s 263 on the ground that the transaction was an “international transaction” u/s 92B and that the AO ought to have referred the matter to the TPO to determine whether the investments were made at arm’s length. The assessee filed an appeal before the Tribunal in which it argued (i) that an investment in the share capital of another company was not an “international transaction” u/s 92-B and (ii) as there was no “income“, the transfer pricing provisions did not apply. HELD by the Tribunal upholding the plea:

An amount paid for investment in share capital of subsidiaries outside India is not in the nature of an “international transaction” as defined in s. 92-B. Transfer pricing provisions are not applicable to transactions where there is no income (Circular No. 14, dated 22/11/2011, Dana Corporation 321 ITR 178 (AAR) & Amiantit International 322 ITR 678 (AAR) referred)

 
 
Home | About Us | Terms and Conditions | Contact Us
Copyright 2018 CAinINDIA All Right Reserved.
Designed and Developed by Binarysoft Technologies Pvt. Ltd.
Binarysoft Technologies - Achievements

Transfer Pricing | International Taxation | Business Consulting | Corporate Compliance and Consulting | Assurance and Risk Advisory | Indirect Taxes | Direct Taxes | Transaction Advisory | Regular Compliance and Reporting | Tax Assessments | International Taxation Advisory | Capital Structuring | Withholding tax advisory | Expatriate Tax Reporting | Litigation | Badges | Club Badges | Seals | Military Insignias | Emblems | Family Crest | Software Development India | Software Development Company | SEO Company | Web Application Development | MLM Software | MLM Solutions