IIRF Online > Finance & Accounting > Taxes > Transfer Pricing > Transfer pricing assessment, APA and Intra-group services
Transfer pricing assessment, APA and Intra-group services by Coursera
Course Highlights
- Understand the academic and practical aspects of the Indian transfer pricing assessments and appeal.
- Learn about the penalty provisions as prescribed under the Indian transfer pricing laws.
- Describe the concept of APA and its importance along with the legal provisions governing the practical and procedural aspects.
Skills you will learn!
Curriculum
17 Topics
Introduction to the module
Overview of the TP assessment procedure
Role and powers of AO and TPO in assessments
Important timelines
Penalties
Key takeaways
Legal provisions - Reference to TPO
CBDT guidelines on TP assessments
Gujarat HC on reference to the TPO
SC judgement on proper elements of a show-cause notice
SC judgement on passing of a speaking order
Legal provisions - Powers of TPO
Practice assessment: Overview of the TP assessment procedure
Practice assessment: Role and powers of AO and TPO in assessments
Practice assessment: Important timelines
Important timelines: Penalties
Graded assessment: TP assessments time limits and penalties
16 Topics
Introduction to the module
APA introduction
India APA overview
Indian APA process
APA signing
APA Compliances
APA revision/Cancellation/ Renewal
Key takeaways
CBDT guidance note on APA
Legal provisions - APA
Forms for filing and processing of APA
CBDT's annual report on APA
Practice assessment:APA introduction
Practice assessment: India APA overview
Practice assessment: Indian APA process
Graded assessment: Overview of APA
17 Topics
Introduction to the module
Intra-group services - An Overview
Need-benefit test and Arm’s length analysis
Litigation landscape of intra-group services
Key contents of a defence file
Intra-group services-Transfer pricing and GST Interplay
Key takeaways
OECD & UN Guidelines on Intra-group services
Mumbai ITAT in the case of Dresser-Rand India Private Limited
Delhi HC - Cushman and Wakefield India Pvt Ltd.
Bangalore ITAT in the case of Fosroc Chemicals
Delhi HC in the case of CIT vs EKL Appliances Ltd.
Practice assessment: Intra-group services - An Overview
Practice assessment: Need-benefit test and Arm’s length analysis
Practice assessment: Litigation landscape for IGS and defence file
Graded assessment: Intra Group Services
Hands on project: Transfer pricing assessment APA and Intra-group services
Transfer pricing assessment, APA and Intra-group services
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