The December 2014 issue of Direct Tax Amicus features an article on taxation of Engineering, Procurement and Construction (EPC) contracts which involve complex issues like existence of Permanent Establishment (PE), whether offshore supplies are taxable as FTS and transfer pricing issues. Ratio Decidendi section of this issue covers case laws pertaining to, among others, mutual arrangements being subject to transfer pricing, joint development agreement with conditional possession being a taxable transfer and premature payment of deferred sales tax not being a remission of trading liability.
December, 2014/Issue-05