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Articles by RAGHAV GUPTA

Key point and analysis of final rule on range concept and use of multiple year data

Posted by RAGHAV GUPTA 30 October 2015 9645 Views

Key Point and Analysis of Final Rules on �Range Concept� and �Multiple year data� in Transfer Pricing provisions IntroductionThe Income-tax Act provides for determination of income having regard to Arm�s Length Price (A

TP Alert | Vodafone Case: Bom HC decoded applicability of TP

Posted by RAGHAV GUPTA 14 October 2014 20665 Views

Vodafone Case Summary: Bombay HC rules on the applicability of TP provisions to issue of shares to associated enterprises; holds share premium does not give rise to incomeSection 92(1) of the Income Tax Act (Act) states th

Transfer pricing issues relating to royalty payment

Posted by RAGHAV GUPTA 04 October 2014 30967 Views

Royalty payment has been a matter of intensive discussion in India as well as internationally. Recently, the Organisation for Economic Cooperation and Development (OECD) published discussion paper on Base Erosion and Profit Shifting (BEPS) in which i

A Year with Specified Domestic Transaction (Transfer pricing)

Posted by RAGHAV GUPTA 19 September 2014 20806 Views

The Income Tax Act 1961(The Act) as amended by Finance Act 2012 brought specified domestic related party transactions (SDT) within its fold with effect from FY 2012-13 vide section 93BA of the Act and admittedly as with any new legislat