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Income Tax - Highlights / Catch Notes

Home Highlights May 2014 Year 2014 This

Applicability of Transfer pricing provisions - Transactions with ...

Income Tax

May 16, 2014

Applicability of Transfer pricing provisions - Transactions with joint venture - transactions between the assessee and IJMII do not fall under section 92B(2) - Provisions of transfer pricing not applicable - AT

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  1. Applicability of Transfer pricing provisions - transactions with joint venture - transaction with associated enterprises - international transaction - DTAA with Malaysia...

  2. Joint Venture - taxable services provided by the members of the Joint Venture (JV) to the JV and vice versa and inter se between the members of the JV-reg.

  3. Transfer pricing adjustment - applicability of CUP to a single combined international transaction of Import of Crystal goods and Crystal components, cannot be considered...

  4. A “joint venture” would mean a joint arrangement, entered into in writing, whereby the parties that have joint control of the arrangement, have rights to the net assets...

  5. Provisions of section 194C are not attracted in the case of payments made by the Joint Venture to its constituent members - Relied upon KCEL-MEIL (JV) [2015 (1) TMI 744...

  6. Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

  7. Nature of receipt - option price received against to sell the shares of the joint-venture company - After considering all these facts the Dabur has invested into the...

  8. Classification of services - Business Support Services or not - Joint venture - co-developer or agent - if strictly go through the above agreement, it is nowhere...

  9. Levy of service tax - contribution to Joint Venture / Partnership arrangements - it is clearly impermissible to hold that the contribution made by a co-venturer...

  10. Credit of TDS can be given only in the hands where income therefrom is subjected to tax. If accrual of income in respect of the receipts received dejure by joint venture...

 

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