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H P Agrawal

H P Agrawal

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  • Transfer pricing deals: Compulsory scrutiny limit tripled to Rs 15 cr

    01-09-2013 22:28:00

    It is a well known fact that transfer pricing (TP) provisions have fuelled unprecedented litigation in India.TP provisions were introduced in India by the Finance Act, 2001, so as to protect India's right to collect a fair share of tax in respect of ...

  • Draft safe harbour rules disappoint

    18-08-2013 21:20:00

    In an effort to reduce transfer pricing ('TP') litigation, Section 92CA was introduced by the Finance Act (No. 2), 2009, authorising the Central Board of Direct Taxes (CBDT) to formulate safe harbour rules. By way of the above amendment, CBDT was ...

  • Tax refund made easy by Delhi High Court

    04-08-2013 22:28:00

    Revenue authorities have their own targets for tax collection. The targets are often based on the collections made in the earlier year without any regard to the estimated actual profits to be made by the tax payers. The tax officers are so obsessed ...

  • Tax treaties override Vodafone amendments

    14-07-2013 21:10:00

    AP High Court, in the case of Sanofi Pasteur Holding SA, said amendments made in the I-T Act do not nullify India's tax treaties

  • India ensures tax equalisation for international posting

    30-06-2013 21:09:00

    There are a large number of multinational companies operating in India. In case of multinational companies, it is a common practice that their employees are transferred from one country to other countries for serving offices situated in various ...

  • Rule 10H on pre-filing consultation: A unique feature of Advance Pricing Agreements

    16-06-2013 23:28:00

    Finance Act, 2012, introduced the concept of Advance Pricing Agreements (APA). APAs are common in other developed countries.An Advance Pricing Agreement (APA) is an agreement between the taxpayer and the tax authorities on the pricing of ...

  • Insurance valuation: A good benchmark for transfer pricing

    02-06-2013 21:09:00

    Irrespective of the difficulties, taxpayers have to comply with the transfer pricing regulations and determine the arm's length price

  • Transfer pricing: Tolerance margin needs to be rationalised

    19-05-2013 21:09:00

    When transfer pricing provisions were introduced in India in the year 2001, no tolerance limit was prescribed for adjustment in arm's length price (ALP). Thus any difference between the ALP, as calculated by adopting an appropriate prescribed ...

  • Information sharing with foreign countries may help tackle black money

    21-04-2013 21:29:00

    The problem of black money in India has reached to a point that the entire political spectrum is committed to bring back the black money illegally stashed outside India. The Government of India is taking serious steps in this direction, including ...

  • R&D issues in transfer pricing clarified

    07-04-2013 22:29:00

    Transfer Pricing (TP) Provisions were introduced in India by the Finance Act, 2001. The TP Provisions were introduced with an intent to protect India's right to collect a fair share of tax in respect of cross-border transactions. In simpler terms, ...

  • Libor - a good benchmark for transfer pricing

    24-03-2013 22:29:00

    Interest rates in India are quite high compared to the rates prevailing outside of the country

  • HP Agrawal: A mixed bag for foreign companies

    10-03-2013 22:29:00

    A welcome feature of Finance Bill, 2013, is that it does not contain retrospective amendments and does not seek to overrule pronouncements of Supreme Court. There are only a few proposals in the Budget relating to foreign enterprises. Our ...

  • HP Agrawal: Is royalty paid by a non-resident to another taxable in India?

    24-02-2013 21:28:00

    The issue for consideration is as to whether the royalty paid by the foreign manufacturers on manufacturing of the goods outside India could also be taxed in India if such goods are sold in India. In terms of section 9(1)(vi)(c), royalty payable by ...

  • HP Agrawal: Controversy on definition of international transaction

    11-02-2013 00:18:00

    LG Electronics Inc, a Korean company, set up a wholly owned subsidiary in India (LG Electronics India Pvt Ltd). LG Korea provided its technical assistance to LG India for which it agreed to pay royalty at the rate of one per cent. LG Korea also ...

  • HP Agrawal: Standard rules not the only method to calculate arm's length for TP

    14-01-2013 00:17:00

    Transfer Pricing (TP) provisions were introduced in India by the Finance Act 2001. The TP provisions were introduced with an intent to protect India’s right to collect a fair share of tax in respect of cross border transactions. In simpler terms, ...