F. No. 500/54/2012-FTD.I
Government of India
Ministry of Finance
Department of Revenue
Central Board of Direct Taxes
Foreign Tax & Tax Research Division-I
Room No. 907, ‘C’ Wing,
Hudco Vishala Building,
Bhikaji Cama Place, R.K. Puram, N. Deihi
Dated 22.03.2012
OFFICE MEMORANDUM
Subject: ADVISORY GROUP FOR INTERNATIONAL TAXATION AND TRANSFER PRICING IN DEPARTMENT OF REVENUE, MINISTRY OF FINANCE REG
In order to reduce tax litigation and bring tax certainty in the area of international taxation and transfer pricing, an ‘Advisory Group for International Taxation and Transfer Pricing’ has been set up comprising of following members:
i. Revenue Secretary to the Government of India-Head of the Advisory Group
ii. Chairman, Central Board of Direct Taxes, Department of Revenue-Member
iii. Director General of Income-tax (International Taxation), New Delhi, Member
iv. Joint Secretary (FT&TR-I) Department of Revenue Member
v. Joint Secretary (Fi&TR-II), Department of Revenue Member
vi. Joint Secretary (TPL-), Department of Revenue, Member
vii. One representative of CII – Member
viii. One representative Is FICCI -Member
ix. One representative of Assocham – Member
x. One representative of ICAI-Member
xi. One tax advisor of repute to be nominated by Revenue Secretary
xii. Any other person that the committee may wish to invite.
Terms of Reference:
The advisory group can have consultation an emerging issues of taxation In the area of international taxation and transfer pricing to understand each others view points and also with a purpose to reduce litigation and bring in more tax certainty. The group can also advice the government about legislative amendments & administrative measures which can help reduce litigation and bring in more tax certainty.
Dr. Satya Pal Kumar
Under Secretary to the Government of India
It is a good attempt to find out a new way for clear understanding and hasselfree solution on the subject matter which is major issue of the day. However I am hopeful some way will come out from new advisory committee’s view of Report.
Let the report be widely published. May the members of the Committee have courage of writing a “dissenting report” or a “dissenting note” on part of the report in case they do not agree with the majority view. Let such dissenting note / dissenting report also be widely published (as part of the published report). May God give the members of the Committee the power of conviction, the selflessness in their work and the vision and wisdom to uplift the Economy. A Very Good beginnning indeed.
A GOOD BEGINING.
REQUEST SAME TYPE OF COMMITTEEE BE SET UP FOR DOMESTIC TAXATION ALSO. BECAUSE THE LITIGATION IS INCREASING. THERE ARE GIFTS IN THE FORM OF PREFERRED LOCATION TRANSFERS TO THE TARGET ACHIEVERS. THERE ARE NO GIFTS FOR THE ZERO DISPURE AO.
TO ACHIEVE MY TARGET I NEED NOT THINK OF THE ASSESSEE. YOU HAVE TO BE A WINNER BY HOOK OR CROOK.
IN BUDGET THEY HAVE COME UP WITH GAAR. THIS IS GOING TO ADD MAJOR TROUBLE TO THE CUSTOMERS, LITIGATIONS IN ITAT, HC AND SC AND FEES IN THE POCKETS OF PROFESSIONALS.
Khuda ke ghar me der hain magar andher nahi