International Business and Transfer Pricing Concept and Jurisprudence
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9789349957718

About the Book

International Business and Transfer Pricing written by Shri S.C. Mishra and edited by Shri S. P. Singh, represents a profound integration of legal principles, economic theories, and judicial precedents spanning global commerce evolution. Structured across six chapters, the book examines international trade from ancient explorations to digital MNEs, intra-group structures, the Arm's Length Principle with DEMPE analysis, global frameworks from 1928 Revenue Act through BEPS, and India's regime comparisons.Authored by a distinguished scholar whose "insistence on clarity, structured reasoning, and analytical precision" marked his tenure in the Indian Revenue Service at various senior positions as policy maker and as administrator, this volume reflects lifetime scholarship and professional excellence. This book combines conceptual depth with practical relevance—connecting statutory provisions with business realities while maintaining characteristic brevity. As the editor has noted, it is "a goldmine for students." This volume is a tribute to Shri Mishra’s intellectual legacy that makes it an essential reading for tax professionals, policymakers, and students.

S C Mishra

S C Mishra was former Director- General of Income-tax and author of Transfer Pricing Manual and Transfer Pricing in India: From Inception to BEPS. His areas of specialisation include tax policy, capacity building and training. He had wide experience in legislative drafting and amendment of direct tax laws. He participated in programmes on training methods, tax treaties and comparative tax laws in India and overseas. He also conducted training programmes on taxation of non-residents. He was invol.......

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S P Singh

SP Singh (SP) Editor of this book is presently Senior Advisor to the Institute of Chartered Accountants of India (ICAI). He started his career in 1976 as a lecturer of Physics in St. Xavier's College. Ranchi. In 1979 he joined the Indian Revenue Service where he served for over two decades in various capacities. While in the Foreign Tax & Tax Research Division he was part of the team for negotiating and finalising several tax treaties. He was a member of the Expert Croup on Transfer Pricing cons.......

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