MNC can now appeal with CIT (A) too in respect of transfer pricing related disputes
Feb 1, 2010 Income Tax
This is good news for Multi-national companies (MNCs) operating in India. Over 1,600 such companies, who were asked to pay additional corporate taxes on account of their overseas transactions, now, have the option to appeal before the conventional forum of Commissioner (Appeal) as well as Dispute Resolution Panel (DRP) for redressal of their grievances. An appeal before the commissioner (Appeal) may take a year or two for a decision.
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Tags: Dispute Resolution Panel, drp, overseas transactions, tpo, Transfer Pricing
Clarification regarding filing of Objections before Dispute Resolution Panel (DRP)
Jan 29, 2010 Income Tax
F. No. 142/22/2009-TPL (Pt. II) , Dated: 20th January 2010
Subject: Clarification regarding filing of Objections before Dispute Resolution Panel (DRP) – reg
A new section 144C was inserted in the Income-tax Act, 1961 vide Finance (No. 2) Act of 2009. Section 144C provides for constitution of a Dispute Resolution Panel (DRP) to decide cases of an eligible assessee as defined in sub-section (15) of section 144C of the Income-tax Act. The Dispute Resolution Panel Rules were notified vide SO No. 2958 (E) dated 20th November 2009.
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Tags: clarification, department of revenue, Dispute Resolution Panel, draft assessment, drp, income tax act, income tax act 1961, international taxation, objection, taxpayers, tpl
Income-tax dispute resolution panel may hit tax collection by Rs 10,000-crore
Jan 1, 2010 Income Tax
The government’s tax collections could take a Rs 10,000-crore hit this year due to the setting up of the income-tax dispute resolution panel (DRP) for settling transfer pricing disputes. Such a dispute arises when there is a disagreement between the government and the taxpayer, especially a foreign company, in determining the tax liability of its subsidiary.
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Tags: developed countries, disagreement, Dispute Resolution Panel, draft assessment, drp, finance ministry official, Income tax department, objections, revenue target, shortfall, tax collections, tax dispute resolution, tax liability, taxpayers
Dispute Resolution Panel – Housing Project
Dec 13, 2009 Income Tax
1. Preamble
The present article discusses amendment proposed by Finance Bill (No. 2) 2009 regarding provisions of Dispute Resolution Panel (DRP) and deduction u/s. 80-IB(10).
Though the provisions relating to Dispute Resolution Panel are not a complete code for full and complete resolution of dispute referred to it, it is a step in right direction.
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Tags: alternative dispute resolution, CBDT, direct taxes, dispute resolution mechanism, Dispute Resolution Panel, drp, finance bill, Income Tax, international transaction
Dispute Resolution Panel (DRP) to resolve tax disputes of the foreign companies expeditiously
Dec 1, 2009 Income Tax
The Finance Act, 2009 inserted a new section 144C in the Income-tax Act providing an alternate mechanism to resolve tax disputes of the foreign companies expeditiously. The Finance Minister, taking cognizance of delays, which take place in any tax litigation, declared in the parliament that “The dispute resolution mechanism presently in place is time consuming and finality in high demanding cases is attained only after a long drawn litigation till the Supreme Court.
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Tags: alternate dispute resolution, CBDT, cognizance, dispute resolution mechanism, Dispute Resolution Panel, drp, fast track, finance act, finance minister, foreign investment, income tax act, international transaction, tax dispute resolution, Tax disputes, tax litigation, time consuming, track basis
Dispute resolution panels will allow MNCs to sort out their tax disputes in faster and cost effective manner
Nov 24, 2009 Income Tax
Multinational companies can now look forward to expeditiously settling their tax disputes in India. The Central Board of Direct Taxes on Monday announced the new rules for creation of special dispute resolution panels (DRP) that will allow foreign taxpayers to sort out their tax disputes in a faster and cost effective manner.
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Tags: direct taxes, draft assessment, drp, drps, mnc, mncs operating in india, multinational companies, tangible assets, tax authorities, Tax disputes, tax liability, tax partner
Dispute Resolution Panel, National Tax Code, Returns and assessment procedures, Appeal, revision and penal provisions in Direct Tax code
Aug 20, 2009 Income Tax, direct tax code
Self reporting of Tax Bases & Acknowledgment [Section 148 & 154]
1. Similar to the concept of filing return of income, taxpayers have been required to file ‘Return of Tax Bases’ (‘RTB’)
2. The RTBs have to be filed on or before:
• 30th June – If the person is not a company and does not derive income from business
• 31st August – In all other cases
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Tags: APPEAL, assessment section, direct tax code, Dispute Resolution Panel, drp, dtc, electronic acknowledgment, Income Tax Scrutiny, income taxpayers, National Tax Code, ntc, partnership firm, rectification, Returns and assessment procedures, revision, risk management strategy, rtb, Scrutiny, Scrutiny Assessment, tax assets, tax returns, Tax Treaty, unincorporated bodies