Union Budget Bulletin : 2021-22


The Finance Minister has introduced the Budget 2021 in the Parliament amidst the great turmoil caused globally by the pandemic. All governments have had to grapple with the human and economic travails. The budget aims to increase public spending to steer the economy from its worst contraction in decades. In these dire circumstances, the budget has proposed amendments to the Income-tax Act, 1.....

08 Feb 2021

An Analysis of key Amendments in the Finance Act, 2020 (Direct Tax and Equalisation Levy)


The President has given assent on 27 March 2020, to the Finance Act, 2020 passed by the Parliament with many amendments. Enclosed herewith is an analysis of the key direct tax amendments made along with the changes made to the provisions of equalisation levy, to the Finance Bill, 2020, which have wide ramifications. CLICK HERE TO READ. .....

21 Apr 2020

VTPA Tax Bulletin - An Analysis of The Direct Tax Vivad Se Vishwas Act, 2020 (Amended)


Dear Reader, The Parliament has promulgated “The Direct Tax Vivad Se Vishwas Act, 2020” (the Scheme) with the aim of reducing the pending litigation in respect of the direct tax matters. The Scheme has been amended, providing clarifications on certain debatable issues and its coverage has also been widened. Please find enclosed herewith VTPA Tax Bulletin&nb.....

27 Feb 2020

Mumbai ITAT holds that reduction in share capital amounts to a ‘transfer’ u/s 2(47) and thereby gives rise to capital gain - M/s. Carestream Health Inc.


The Hon’ble Mumbai Income-tax Appellate Tribunal (Mum ITAT) has evaluated and held that the reduction in share capital amounts to a ‘transfer’ u/s 2(47) and thereby gives rise to capital gains, if consideration is paid for such reduction. Please find attached herewith our Tax Bulletin on the decision of the Mumbai ITAT in the case of Carestream Health Inc. CLICK HERE TO REA.....

18 Feb 2020

An Analysis of The Direct Tax Vivad Se Vishwas Act, 2020


The Parliament has promulgated “The Direct Tax Vivad Se Vishwas Act, 2020” ( the Scheme) with the aim of  reducing the pending litigation in respect of the direct tax matters. The Scheme, is strict in its application and also in the litigation to be covered. The Scheme could have been more liberal and encompassed other connected litigation to fulfill its aim to curb litigation......

06 Feb 2020

Union Budget Bulletin : 2020-2021


In the backdrop of the economic slowdown, the Hon’ble Finance Minister has presented the 2020 Union Budget. However, the budget does not live up to the expectations of the various stakeholders. The largesse shown to the corporate sector, by the Taxation Laws (Amendment) Act, 2019, has not been followed up with any concession to individual taxpayers, which could have given a.....

03 Feb 2020

Overview of Transfer Pricing Regulation - BCAS


Please view our Presentation given before the Bombay Chartered Accountant Society on Overview of Transfer Pricing Regulation. CLICK HERE TO READ. .....

18 Jan 2020

Key Amendments to the Finance bill No. 2, 2019 as passed by Lok Sabha


The Lok Sabha has passed the Finance (No. 2) Bill, 2019 on July 18, 2019, which was presented originally in the Lok Sabha on July 5, 2019. Certain changes have been made to the original Bill. An analysis of the key direct tax amendments is enclosed herewith .....

23 Jul 2019

Budget Bulletin : 2019-2020


In the first budget after the formation of new government, India's first lady full-time Finance Minister has provided a thrust to the infrastructure, digital, startup and agrarian economy, with the hope that it may stimulate growth. Enclosed herewith is the Tax Bulletin analyzing the direct tax proposals as stated in the Budget. .....

05 Jul 2019

Bombay High Court holds that the CBDT is not empowered to offer incentives to CIT(A) to pass an order enhancing or levying penalties


Bombay High Court Ruling: The CBDT is empowered to lay down broad guidelines for disposal of appeals by CIT(A). However, it cannot offer ‘incentives’ to CIT(A) for making enhancement and levying penalty. Such policy transgresses the exercise of quasi-judicial powers of the CIT(A) and is wholly impermissible and invalid under section 119 of the Act.   The Chamber of Tax Consu.....

25 Apr 2019

Supreme Court lays down the maintainability of a review petition before High Court on dismissal of a Special Leave Petition


  Supreme Court Ruling: Effect of dismissal of SLP filed before the Supreme Court Khoday Distilleries Ltd. vs. Mahadeshwara Sahakara Sakkare Karkhane Ltd. [Civil Appeal No. 2432 and 2433 of 2019] / [2019] 104 taxmann.com 25 (SC) Facts of the case: Mahadeshwara Sahakara Sakkare Karkhane Ltd. (MSSKL) had recoverable dues of around INR 1,00,76,630/- crores, along with interest.....

22 Apr 2019

Recent Developments in Transfer Pricing - BCAS


Please view our Presentation given before the Bombay Chartered Accountant's Society on Recent Developments in Transfer Pricing. .....

18 Apr 2019

Bombay High Court holds that the transfer pricing officer cannot suo-motu assume jurisdiction to determine the arm’s length price of specified domestic transactions not referred to him by the assessing officer


Bombay High Court Ruling: Whether the Transfer Pricing Officer can examine any specified domestic transaction, even if the same is not specifically referred to him by the Assessing Officer?   Times Global Broadcasting Company Ltd vs. Union of India & Ors.  [Writ Petition No. 3386 of 2018] [2019] 103 taxmann.com 388 (Bombay)   Facts of the case:   .....

28 Mar 2019

Bombay HC holds that direct and indirect shareholding in a company cannot be clubbed for the purposes of determining the threshold of ‘substantial interest’ as specified in explanation (a) to section 40A(2)(b) of the Act


Bombay High Court Ruling:   The shareholdings of parent company and its subsidiary cannot be clubbed for the purposes of determining the threshold of ‘substantial interest’ as specified in explanation (a) to section 40A(2)(b).   Acquisition of an asset (purchase of loans) from subsidiaries would not amount to  expenditure and is thus not a specified .....

02 Jan 2019

Permanent Establishment - Analysis of Recent Ruling in the case of Samsung - IBFD Journal


Please read our article on the topic - Analysis of the Samsung Case on the Determination of a Permanent Establishment for Services Provided by Seconded Employees of a Korean Parent to Its Subsidiary in India. The said article is published by the International Bureau of Fiscal Documentation (popularly known as IBFD) in The International Transfer Pricing Journal, number 5, volume 25, the S.....

25 Sep 2018

If no income accrues or arises or is received by the assessee under section 5, no notional income can be brought to tax under section 92 of the Act - Shilpa Shetty


Mumbai ITAT Ruling - Section 92 of the Act is not an independent charging section to bring in a new head of income or to charge tax on income which is otherwise not chargeable under the Act. Accordingly, the ITAT held that, if no income accrues or arises or is received by the assessee under section 5, no notional income can be brought to tax under section 92 of the Act.   Shilpa Shetty .....

31 Aug 2018

Permanent Establishment - Analysis of Recent Rulings on Nokia Networks and MasterCard - CTC Journal


Please read our article on ‘Permanent Establishment - Analysis of Recent Rulings (MasterCard and Nokia Networks)’, published by the Chamber of Tax Consultants, in Hot Spot column - July 2018. .....

27 Jul 2018

Key amendments to Form No. 3CD - Notification No. 33/2018


The Central Board of Direct Taxes (CBDT) vide Notification No. 33/2018/F.No. 370142/9/2018-TPL dated 20 July 2018 has amended the Income-tax Rules, 1962 (the Rules), under the powers conferred by section 44AB read with section 295 of the Income-tax Act, 1961 (the Act). Following are key new reporting requirements incorporated in Form no. 3CD and the same are effective from 20 August 2018:  .....

25 Jul 2018

Analysis of the Supreme Court judgments of Morgan Stanley & Co Inc. and Formula One World Championship Ltd - CTC Publication


Please read our article on Analysis of the Supreme Court Judgments on Permanent Establishment of Morgan Stanley & Co. Inc. and Formula One World Championship Ltd. The said article is published by the Chamber of Tax Consultants (CTC) in its Publication on 101 Supreme Court Landmark Judgments, encompassing within its ambit Direct and Indirect Taxes and Allied Laws.   .....

16 Jul 2018

Bombay HC decides whether CUP method can be applied to Customised Goods: IBFD's Journal (July 2018)


Please read our article on The Bombay High Court Decides Whether the CUP Method Can Be Applied to Customized Goods published by the International Bureau of Fiscal Documentation (popularly known as IBFD) in The International Transfer Pricing Journal, number 4, volume 20, the July/August 2018 issue, under the topic Derivatives & Financial Instruments. .....

01 Jul 2018

Final Notification of exception, modification and adaptation in respect of foreign company said to be resident in India under Section 115JH of the Act - Notification No. 29/2018/ F No. 370142/19/2017-TPL


The CBDT has issued the Final Notification No. 29/2018 dated 22 June 2018 (applicable from AY 2017-18) for exception, modification and adaptation in respect of a foreign company said to be resident in India due to its place of effective management (POEM) being in India, under Section 115JH of the Income-tax Act, 1961 (the Act). This is on the similar lines of the draft notification. To read our ta.....

29 Jun 2018

AAR holds that the applicant has a PE in India as regards the use of a global network and infrastructure to process card payment transactions for customers in India - MasterCard Asia Pacific Pte Ltd


Authority for Advance Rulings, New Delhi– Whether the Applicant has a permanent establishment in India as regards the use of a global network and infrastructure to process card payment transactions for customers in India and as regards other related issues? MasterCard Asia Pacific Pte Ltd, In re. [AAR No. 1573 of 2014] / [2018] 94 taxmann.com 195 (AAR - New Delhi)   Fac.....

22 Jun 2018

A subsidiary in India does not constitute a permanent establishment of the parent company as held by the majority view of Delhi ITAT Special Bench - Nokia Networks OY


Delhi ITAT (Special Bench) Ruling – Whether the Indian subsidiary of the assessee constitutes Permanent Establishment (PE) of the assessee in India on account of ‘signing, networking, planning and negotiation of offshore supply contracts in India’? If yes, whether any profit is attributable to the same, and the quantum thereof?   M/s. Nokia Networks OY vs. JCIT, New De.....

13 Jun 2018

The SC has allowed a deduction of lease equalisation charges, on the basis of the Guidance Note issued by ICAI


Supreme Court Ruling – The Guidance Note issued by Institute of Chartered Accountants of India on lease rental income which helps to compute lease equalisation charges, held to be allowable as a deduction. There is no express bar in the Income-tax Act, 1961 regarding the application of such accounting standards. CIT-VI vs. Virtual Soft Systems Ltd.     [Civil Appeal Nos......

02 May 2018

SC rejects dominant purpose test for exclusion of strategic investments in calculation of disallowance u/s 14A - Maxopp Investment Ltd.


Supreme Court (SC) Ruling – Whether the expenditure incurred (including interest paid on funds borrowed), while purchasing the shares/ stocks of a company for the purpose of gaining control over the investee company or as 'stock-in-trade' (i.e. as a business activity) and not as investment to earn dividends, can be treated as expenditure ‘in relation to income i.e. dividend inc.....

17 Mar 2018

Key Amendments to the Finance Bill, 2018 passed by Lok Sabha


The Lok Sabha has passed the Finance Bill, 2018 with a few amendments. Enclosed is an analysis of the amendments, for your reference. .....

15 Mar 2018

Budget Bulletin : 2018-2019


In the first budget since the end of demonetization and GST went online, the Finance Minister has again provided a thrust to the rural and agrarian economy, with the hope that it may stimulate growth. Enclosed herewith the Tax Bulletin analyzing the direct and indirect tax proposals as stated in the Budget. .....

01 Feb 2018

Master File and Country-by-Country Report - CVOCA's News and Views (Feb 2018)


In order to align with the global 3-tier documentation requirements for preventing erosion of tax base, India has legislated the reporting requirements for global and Indian multinational enterprises in the form of Master File and Country-by-Country Report. Please read our Article published by the CVO CA Association, in Feb 2018, ‘CVOCA's News and Views Journal’.....

01 Feb 2018

Does omission of SDT by Finance Act 2017, renders it non-existent from inception: Yes ITAT - Texport Overseas Pvt. Ltd.


The Hon’ble Income-Tax Appellate Tribunal, Bangalore, in the case of Texport Overseas Pvt. Ltd. (‘the taxpayer’) held that the omission of clause (i) of section 92BA (definition of Specified Domestic Transaction) by virtue of the amendment of Finance Act, 2017 w.e.f. 01.04.2017, which referred to payments made to related parties covered under section 40A(2)(b).....

23 Jan 2018

CBDT notifies Final Rules for furnishing Master File and Country-by-Country Report (Notification No. 92/2017)


CBDT notifies Final Rules with respect to Master File and Country-by-Country report (Notification No. 92/2017)   The CBDT vide Notification No. 92/2017 on October 31, 2017 issued Final Rules (Rule 10DA and 10DB) in respect of keeping, maintaining and furnishing information and documents with respect to Master File and Country-by-Country report (CbCR), as per section 92D and section 286 .....

03 Nov 2017

Final Guidance on Place of Effective Management - IBFD (Sept/ Oct 2017)


Please read our article published in The International Transfer Pricing Journal September/ October 2017 Edition on Final Guidance of Place of Effective Management. The Final Guidelines provide guidance on determining the place of effective management for purposes of the residence in India of foreign companies. .....

01 Sep 2017

Draft Notification of exception, modification and adaptation in respect of foreign company said to be resident in India under Section 115JH of the Act - Notification No. F No. 370142/19/2017-TPL


The Central Board of Direct Taxes (CBDT) on June 15, 2017 issued a Draft Notification (notification) vide F No. 370142/19/2017-TPL for exception, modification and adaptation in respect of foreign company said to be resident in India due to the place of effective management (POEM) being in India, under Section 115JH of the Income-tax Act, 1961 (the Act). This notification shall be deemed to ha.....

20 Jun 2017

Buddh International Circuit constitutes a fixed place PE of Formula One (SC) - Formula One World Championship Limited


The Hon’ble Supreme Court held that Buddh International Circuit constitutes a fixed place permanent establishment (PE) of the foreign taxpayer (Formula One) where the commercial/ economic activity of conducting F-1 Championship was carried out.   Supreme Court of India Formula One World Championship Limited vs. Commissioner of Income-tax, International Taxation - 3, Delhi &.....

01 May 2017

GE overseas group entities have PE in India (Delhi ITAT) - GE Energy Parts Inc.


The Hon’ble Delhi Income-tax Appellate Tribunal (ITAT) has observed that employees of the foreign enterprise assigned to India for performing marketing and sales functions for the overseas group entities, used the liaison office of one of the group entities in India. Thus, the ITAT held that the assessee had both, a fixed place permanent establishment (PE) and agency PE, in India.  &.....

25 Feb 2017

Budget Bulletin : 2017-2018


The Finance Minister in his Budget presented to the Parliament today has aimed at giving maximum benefit to the rural, infrastructure, agricultural sector, etc. in the hope that there would be a fillip to the economy. Trust you will find it an interesting read.   .....

01 Feb 2017

AO is duty bound to refer the matter to the DVO in case of disagreement with the assessee on value of property sold (Hyderabad ITAT) - Lalitha Karan


The Hon’ble Hyderabad Income-tax Appellate Tribunal (ITAT), in the case of Lalitha Karan held that the AO is duty bound to refer the matter to the DVO as per the provisions of section 50C(2) of the Income-tax Act, 1961, when on the facts and circumstances of the case, the assessee claims that the value adopted by the stamp duty authorities does not represent the fair market value, due to cer.....

10 Jan 2017

Whether an ALP adjustment can be made in respect of interest free loan granted by a non-resident company to its WOS in India [Kolkata ITAT(Special Bench)] - Instrumentarium Corporation Ltd


The Kolkata Tribunal has dealt in detail on the concept of base erosion which was relied by the assessee, as its main argument that attribution of income to the foreign associated enterprise, under transfer pricing law, on account of interest on loan given; would automatically mean a deduction granted in law to the Indian associated enterprise.​   Instrumentarium Corporation Limited, .....

06 Jan 2017

Clarification relating to Indirect Transfer [Section 9(1)(i) of the Act] - Circular no. 41 of 2016


The Central Board of Direct Tax (CBDT) after receiving queries from various stakeholders has issued Circular no. 41 of 2016 providing clarification relating to Indirect Transfer [Section 9(1)(i) of the Income-tax Act, 1961 (the Act)]   Indirect Transfer [Section 9(1)(i)] Section 9(1)(i) was amended vide Finance Act, 2012 w.r.e.f. 01.04.1962, by.....

27 Dec 2016

Fundamental principles of Transfer Pricing and Transfer Pricing audit - Borivali CPE Study Circle


Please view our Presentation given before the Borivali CPE Study Circle of Western India Regional Council (ICAI) on fundamentals principles of transfer pricing and transfer pricing audit. .....

23 Oct 2016

Section 263 of the Act does not require issue of show cause notice unlike Section 147 of the Act (SC) - Amitabh Bachchan


The Hon’ble SC reaffirmed the position under law that CIT is not required to issue any show cause while exercising its suo-motu revision power. The SC having reiterated the position that so long as the view taken by the AO is the possible view, the same ought not to be interfered with by the CIT under section 263 of the Act merely on the ground that there is another possible view of the matt.....

17 May 2016

Draft Guidance of Place of Effective Management - IBFD (May/ June 2016)


Please read our article published in The International Transfer Pricing Journal May/ June 2016 Edition on Draft Guidance of Place of Effective Management. .....

01 May 2016

Constitutional validity of Section 94A of the Act (Madras HC) - T. Rajkumar, K. Dhanakumar & T. K. Dhanashekar


Madras High Court Ruling – Whether Section 94A(1) of the Act is ultra vires Articles 14, 19, 51, 253 and 265 of The Constitution of India (the Constitution) – Whether Notification No. 86 dated 1.11.2013 issued by the CBDT is ultra vires Section 94A of the Act r.w. Articles 14, 19 and 265 of  the Constitution – Whether Press Release issued by Ministry of Finance titled &ldquo.....

15 Apr 2016

Taxation of sportspersons and artistes - GSLTR (March 2016)


Please read our article published in Global Sports Law and Taxation Reports, March 2016 Edition (GSLTR) on Taxation of sportspersons and artistes. .....

01 Mar 2016

Budget Bulletin : 2016-2017


The Finance Minister in his Budget presented to the Parliament today has aimed at giving a fillip to growth and promoting the new age industries. Trust you will find it an interesting read.   .....

29 Feb 2016

Functional, Comparability and Economic Analysis under transfer pricing - BCAS


Please view our Presentation given before the Bombay Chartered Accountant's Society on functional, comparability and economic analysis under transfer pricing. .....

06 Feb 2016

BEPS Action 8-10 Aligning Transfer Pricing Outcomes with Value Creation - focus on law value adding intra-group services - The Chamber’s Journal (Feb 2016)


Please read our Article published by the Chamber of Tax Consultants, in February 2016, ‘The Chamber’s  Journal’ on the BEPS Action Plan with reference to Transfer Pricing - “Action 8-10 Aligning Transfer Pricing Outcomes with Value Creation – focus on law value adding intra-group services”. .....

01 Feb 2016

Proposal on Determination of the Arm’ s Length Price Using the Range Concept - IBFD Journal (Nov / Dec 2015)


Please read our article published in International Transfer Pricing Journal, December 2015 Edition (IBFD) on Proposal on Determination of the Arm’s Length Price Using the Range Concept. The article covers the draft guidelines on the application of range concept under transfer pricing regulations in India.  .....

01 Nov 2015

Instruction on Revised and Updated Guidance for Implementation of Transfer Pricing Provisions


The Central Board of Direct Taxes (CBDT) has issued a very important instruction (Instruction No. 15/2015, dated: October 16, 2015) on the procedure for transfer pricing assessments/audits for international transactions. These instructions will have a far reaching effect on the methodology to be adopted for making reference to the Transfer Pricing Officer (TPO) by the Assessing Officer (AO) and ot.....

17 Oct 2015

Marubeni Case on Benchmarking and Determining Arm’s Length Consideration for the International Provision of Agency and Marketing Support Services - IBFD Journal (Sept/ Oct 2015)


Please read our article published in The International Transfer Pricing Journal September/October 2015 Edition on Ruling in Marubeni Case on Benchmarking and Determining Arm’s Length Consideration for the International Provision of Agency and Marketing Support Services. .....

01 Sep 2015

Constitutional validity of amendment by Finance Act, 2008 to the third proviso to section 254(2A) of the Act (Delhi High Court) - Pepsi Foods Pvt. Limited


  Mumbai ITAT Ruling - Section 92 of the Act is not an independent charging section to bring in a new head of income or to charge tax on income which is otherwise not chargeable under the Act. Accordingly, the ITAT held that, if no income accrues or arises or is received by the assessee under section 5, no notional income can be brought to tax under section 92 of the Act. Shilpa Shetty .....

21 May 2015

Evolving Transfer Pricing Jurisprudence in India - The Bombay Chartered Accountant Journal (April 2015)


Please read our article published in The Bombay Chartered Accountant Journal, April 2015 Edition on Evolving Transfer Pricing Jurisprudence in India. .....

01 Apr 2015

Constitutional validity of the Explanation to section 80-IB(9), added by Finance Act (No.2) of 2009 (Gujarat High Court) - Niko Resources Limited


The Gujarat High Court held - the Explanation added to section 80-IB(9) by Finance Act (No.2) of 2009 defining the term ‘undertaking’ to treat all blocks licensed under single contract under New Exploration Licensing Policy (NELP) as a single undertaking with retrospective effect, held to be unconstitutional, violative of Article 14 of the Constitution and liable to be struck down - th.....

28 Mar 2015

Amendments which are clarificatory in nature, are to be read retrospectively (SC) - Sati Oil Udyog Ltd. & Anr.


The Supreme Court reversed the order of Guahati High Court - definition of “income” in Section 2(24) of the Act is an inclusive one and includes losses also - upheld the clarificatory amendment of Section 143(1A) to be retrospective - the object of Section 143(1A) is the prevention of evasion of tax - provision should apply only to tax evaders - the burden is on the revenue to demonstr.....

25 Mar 2015

Analysis of Vodafone Case on Applicability of Transfer Pricing Provisions to Issuance of Equity Shares - IBFD Journal (March/ April 2015)


Please read our article published in The International Transfer Pricing Journal March/ April 2015 Edition on Analysis of Vodafone Case on Applicability of Transfer Pricing Provisions to Issuance of Equity Shares. .....

01 Mar 2015

Budget Bulletin : 2015-2016


The Finance Minister in his first full Budget presented to the Parliament today has aimed at fiscal prudence with a target to reach 7% growth per annum. With a glimpse of curtailed corporate tax rates and budget allocations for ‘Make in India’, the Finance Minister has highlighted towards growth in industrialization over the long-term tenure. Trust you will find it an interesting .....

28 Feb 2015

Recent Developments in Transfer Pricing - CTC


Please view our Presentation given before the Chamber of Tax Consultants on Recent Developments in Transfer Pricing.  .....

14 Feb 2015

Interpretation of Double Tax Avoidance Treaties - CTC


Please view our Presentation given before the Chamber of Tax Consultants on Interpretation of Tax Treaties. .....

06 Feb 2015

Broad Overview of Transfer Pricing Provisions in India and Current Key Issues faced by Taxpayer - The Chamber’s Journal (Nov 2014)


Please read our article published in The Chambers of Tax Consultants Journal, November 2014 Edition on Broad Overview of Transfer Pricing Provisions in India and Current Key Issues faced by Taxpayer. The article covers mainly the fundamental issues in the practice of transfer pricing for both cross border and specified domestic transactions.  .....

01 Nov 2014

Jurisdictional issue for applicability of Chapter X of the Act (Bombay HC) - Vodafone India Services Pvt. Ltd.


Bombay High Court Ruling – Whether shortfall in premium of shares issued to non-resident holding company is to be considered as income as defined under the Act – Consequently, whether the said shortfall can be treated as deemed loan – Whether a charging provision can be read into Chapter X of the Act to tax notional income – Whether Chapter X is a code in itself   &.....

11 Oct 2014

Provisions of Section 92 come into play only if such income is taxable under the provisions of the Act (Chennai ITAT) - Redington (India) Ltd


Whether TP provisions are applicable to the transaction of gift of shares to AE - Held that a company can also gift - Gift of shares held to be exempt u/s 47(iii) - In the absence of income arising in the case of a gift transaction, provisions of Section 92(1) do not apply - Adjustment on account of corporate guarantee given by assessee on behalf of its AE – Held, no addition on account of o.....

17 Jul 2014

Budget Bulletin : 2014-2015


The new Finance Minister in his first Budget presented to the Parliament today has aimed at fiscal prudence and intends the Budget to be a statement of the fiscal policy of the new government for the next 4–5 years, with a target to reach 7–8% growth per annum. There is also an opening up of the economy by way of FDI of 49% in defence and insurance. ​Trust you will find it an in.....

10 Jul 2014

In absence of any impact on profits, income, losses or assets of an enterprise, no addition can be made on issuance of corporate guarantee (Delhi ITAT) - Bharti Airtel Ltd


Adjustment on account of corporate guarantee given by assessee on behalf of its AE – Held, no addition on account of issuance of corporate guarantee can be made in absence of any impact on profits, income, losses or assets of an enterprise Adjustment on account of notional interest on share application money advanced to AE pending allotment of shares for a long time - Held that, no inter.....

12 Mar 2014

TPO cannot disallow expenditure incurred for purpose of business only at a prima facie level without considering business exigencies (Hyderabad ITAT) - TNS India Pvt Ltd


Hyderabad Tribunal Ruling – Disallowance of management fees by the TPO on the basis that no tangible benefits have accrued to the assessee out of such payment – Whether TPO is justified in disallowing an expenditure in its entirety – When international transactions are benchmarked by applying TNMM[1], can individual expenses be benchmarked again using a different method – H.....

04 Feb 2014

Provisions of taxation for Non-Residents - CTC


Please view our Presentation given before the Chamber of Tax Consultants on provisions of taxation applicable to non-residents. .....

13 Dec 2013

FAR, MAM, Methods and case studies on Specified Domestic Transactions - BCAS


Please view our Presentation given before the Bombay Chartered Accountant's Society on FAR analysis, most appropriate method and case studies on Specified Domestic Transactions under transfer pricing. .....

07 Sep 2013

An overview of Transfer Pricing - WIRC


Please view our Presentation given before the Western India Regional Council of Institute of Chartered Accountants of India on overview of transfer pricing regulationd in India. .....

19 Jun 2013

Specified Domestic Transactions - BCAS


Please view our Presentation given before the Bombay Chartered Accountant's Society on overview of Specified Domestic Transactions under transfer pricing. .....

17 Jan 2013

Introduction to Transfer Pricing Regulations - BCA


Please view our Presentation given before the forum at Bombay Chartered Accountants' Society on transfer pricing regulation in India and its practical applicability alongwith case studies. .....

01 Dec 2011

An overview of International Taxation (Double Taxation Avoidance Agreements) & concepts of Transfer Pricing - WIRC


Please view our Presentation given before the Western India Regional Council of Institute of Chartered Accountants of India on overview of International Taxation (Double Taxation Avoidance Agreements) & concept of Transfer Pricing regulations in India. .....

03 Dec 2010

The Evolution of Transfer Pricing Jurisprudence in India - IBFD Journal (Nov/ Dec 2010)


Please read our article published in The International Transfer Pricing Journal November/ December 2010 Edition on The Evolution of Transfer Pricing Jurisprudence in India. .....

01 Nov 2010

International Decisions on Transfer Pricing - Income Tax Review (July 2006)


Please read our Article published by the Income Tax Review, in July 2006, on the International Decisions on Transfer Pricing. .....

01 Jul 2006

VISION & VALUES


VISION To provide niche and specialised value added services to our clients in excess of their expectations. VALUES The firm is built on three founding pillars viz. Honesty, Integrity and Sincerity. The firm thrives on being value leaders, innovative service providers and trusted business partners in providing end-to-end pratical solutions. .....

01 Jan 1970

ACHIEVEMENTS


Recently, VTPA has been recognised as one of India’s Leading Advisers in Transfer Pricing by Expert Guides publication, Euromoney UK 2017 and 2021. VTPA has been rated by International Tax Review as one of the Best Newcomer Tax Firm in Asia. VTPA has been nominated as India’s leading Transfer Pricing and Tax Consultant by International Tax Review - World Tax and by Euromoney Legal M.....

01 Jan 1970

WHY US


Our team brings a wide gamut of experience in serving clients across the globe. With our diversified clientele, we provide innovative professional tax advisory services. Our focus has been to build strong relationships by providing value added services. We have evolved as a firm of choice for our clients, because of our research, knowledge, ability to provide pratical solutions, personalised.....

01 Jan 1970

In News


India Accepts $241.4 Million from Nokia to Settle Tax Dispute: 24 Apr 2018​ India Exempts Offshore Investment Gains for Foreigners: 2 Feb 2018 India's Profit Shifting Rules May Spur Litigation: Practitioners: 12 October 2017 India Grants Extension for First Goods Tax Payments, Forms: 22 Aug 2017 Corporate Structures ‘Face Heat’ From India's .....

01 Jan 1970

Transfer Pricing


Attainment of Management Objectives Assisting business organizations to attain value potential as per the management vision Mitigating transfer pricing (TP) risk by attributing correct profit to the economic substance of a transaction An end-to-end analysis of the entire value chain and correct demonstration of the actual conduct of business to tax authorities Reducing the g.....

01 Jan 1970
01 Jan 1970

COLLAGE ADDRESS


---Lorem Ipsum Dolor Sit, 22-56-2-9 Sit Amet, Lorem, USA Phone:(00) 222 666 444 Fax: (000) 000 00 00 0 Email: info(at) Follow on: Facebook, Twitter .....

01 Jan 1970
01 Jan 1970

Test


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01 Jan 1970

ABOUT US


VTPA founded by Vispi T. Patel in 2009 is a boutique tax firm specialising in direct tax, transfer pricing, international tax, representating before revenue authorities, tax litigation and exchange control regulation matters. Vispi T. Patel, with an experience of over 37 years in the profession, brings expertise in the areas of domestic and international tax, transfer pricing, globa.....

01 Jan 1970

Tax Litigation


Representing before the Tribunal (ITAT / CESTAT / SAT / NCLT) for various tax and corporate related matters Assisting the clients in  preparation and representation in stay matters Representing clients before other appellate authorities, including the Dispute Resolution Panel Assistance in drafting of appeal memo, submissions, preparation of paperbook, etc. Strategizing the line of.....

01 Jan 1970

Corporate Tax Advisory


Domestic tax planning for various business alternatives Assisting in Tax Planning and restructuring Advisory for various types of transactions Withholding tax analysis, compliance and certification Mitigating compliance risk Assistance in advance tax computations Assistance in computation of corporate taxes and filing returns Assistance in impact analysis&.....

01 Jan 1970

International Taxation


Business Restructuring / Inbound and Outbound Operations Designing an entry strategy Evaluating alternative intermediate holding company jurisdictions Strategy on international tax Tax Treaty Interpretation Permanent Establishment (PE) exposure Attribution of profits to a PE Structuring of revenue / capital flows e.g. Royalty, FTS, Dividend, Interest, Capital gai.....

01 Jan 1970

Regulatory Services


Foreign Trade Policy Representation Services for Procedural and Policy Level Changes before DGFT Obtaining Various License (Advance License, EPCG, SFIS & such others) and Closure Advisory and compliance management under SEZ, EHTP, STPI & EOU Corporate Governance Setting up of codes & Review Processes and structures for operation of boards Risk m.....

01 Jan 1970

INDUSTRY


VTPA  aspire to create innovative and insightful solutions to resolve complex business and tax challenges on the complete spectrum of both direct and indirect tax. Our endeavour is to provide sound legal and professional advice, under one roof, and help organisations in evolving global direct tax compliance policy for mitigating economic and legal risk The team specialises in a w.....

01 Jan 1970

CONTACT US


MUMBAI 121, 12th floor, B-Wing, Mittal Court, 224, Nariman Point, Mumbai - 400 021 Mobile: +91 9867635555  Contact Nos.: +91 22 2288 1091 / 92 Email: vispitpatel@vispitpatel.com .....

01 Jan 1970

Vispi T. Patel


Vispi T. Patel has an experience of over 37 years in Direct Tax, Transfer Pricing, International Tax, Global Structuring and other allied fields of professional work. He is a Fellow member of the Institute of Chartered Accountants of India. He represents the clients before the revenue and appellate authorities, including the ITAT. He has been nominated as India leading Transfer Pricing Consulta.....

01 Jan 1970
01 Jan 1970
01 Jan 1970

Suresh Dhoot


Suresh Dhoot is a Fellow member of the Institute of Chartered Accountants of India, has over 32 years of professional experience in taxation, transfer pricing, compliance and advisory work. He has been advising clients on domestic tax, international tax and transfer pricing matters. He represents the clients before the revenue and appellate authorities, including the Income-tax Appellate Tribun.....

01 Jan 1970

Kejal P. Savla


Kejal P. Savla is a Fellow member of the Institute of Chartered Accountants of India, has over 8 years of professional experience. She has experience in the field of direct taxation, international taxation, transfer pricing. Kejal represents the clients before the revenue and appellate authorities, including the Income-tax Appellate Tribunal. She has authored/ co-authored articles relating to i.....

01 Jan 1970

The Team


The Team consists of experienced qualified professionals i.e. 6 Chartered Accountants, 1 semi-qualified, and 1 office administrator who are committed to add value and optimize the benefits accruing to the clients......

01 Jan 1970