India vs AON Consulting: TRANSFER PRICING CASE
The High Court of Delhi, in its ruling on AON Consulting Pvt. Ltd. v. Principal Commissioner of Income Tax – 1 and Ors. (ITA 244/2024), addressed a …
Category: Asia
India vs SC Lowy P.I. (Lux): International Tax Case
The judgment in SC Lowy P.I. (Lux) S.A.R.L. vs Assistant Commissioner of Income Tax (ACIT) revolved around the denial of treaty benefits under the Dou…
India vs Samsung Electronics: Permanent Establishment Dispute
The High Court of Delhi ruled on appeals filed by the Commissioner of Income Tax (International Taxation) against Samsung Electronics Co. Ltd., challe…
Pakistan vs Interquest Informatics: TRANSFER PRICING CASE
The case revolves around the taxation treatment of receipts received by Interquest Informatics Services, a Netherlands-incorporated company, under agr…
Navigating Hong Kong’s 15% Global Minimum Tax
Hong Kong's adoption of the 15% global minimum tax marks a pivotal shift in its fiscal landscape, aligning with the OECD's Base Erosion and Profit Shi…
Transfer Pricing Challenges with TNMM: Lessons from the SABIC India Case for all Multinationals
The SABIC India case revolves around the rejection of TNMM by the Transfer Pricing Officer (TPO) and the adoption of the residual “other method” u…
Delhi High Court vs ABIC India Pvt. Ltd: TRANSFER PRICING CASE
The High Court of Delhi, in its judgment dated 14 October 2024, upheld the Tribunal’s decision to reinstate the Transactional Net Margin Method (TNM…
Hyatt International vs. India (ADIT)
Hyatt vs India (ADIT) tackles several pivotal issues regarding the attribution of income to a Permanent Establishment (PE) in India, even in cases whe…
General Motors v. ACIT, Circle International Taxation 1(3)(1), New Delhi
The Income Tax Appellate Tribunal (ITAT), Delhi Bench, ruled in favour of General Motors USA in a case revolving around the Double Taxation Avoidance …
Keysight Technologies v. Malaysia: Implications for Transfer Pricing and Tax Compliance
The Keysight Technologies Malaysia case underscores the complexities of transfer pricing and tax compliance. By understanding the court's findings and…