In July 2012, the Prime Minister constituted a Committee to Review Taxation of Development Centers and the lT Sector under the Chairmanship of Mr. N Rangachary, former Chairman CBDT & IRDA. Several eminent tax professionals are a part of the Committee. The Committee has issued a first report dated 14.09.2012 in which it has dealt with several important issues such as (i) approach to taxation of Development Centres, (ii) whether the TNMM or the Profit Split Method or the Global Profit method should be adopted to determine the arms’ length income of these Centres, (iii) general transfer pricing issues which are not specific to the IT Sector (iv) income-tax issues pertaining to the IT Sector such as (a) whether “on-site” development is an export activity, (b) the impact of retrospective amendment of the definition of royalty with regard to taxation of software and transmission charges. The Committee has made far-reaching recommendations on each of the issues
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