Principal Chief Commissioner of Income Tax (International Taxation), New Delhi.

International Taxation is an emerging area of work in the field of Direct Taxes in India. The setup for international taxation is headed by the Principal Chief Commissioner of Income Tax (International Taxation) having its office at New Delhi. The field formation is further divided into three broad categories- International Taxation, Transfer Pricing and Advance Pricing Agreements. Each of these areas of work is headed by Director/Commissioner of Income Tax. Apart from the above, concept of Dispute Resolution Panel (DRP) is introduced in the Income Tax Act, 1961 as an alternative dispute resolution mechanism to resolve disputes relating to transfer pricing adjustments. A brief description of work under various areas of work is given below-

1. International Taxation

   This area of operation is manned by various Directorates of International Taxation and caters to assessment and taxation of income of non-residents which accrue or arises in India. It also looks after the work relating to verification of Form 15CA and 15CB and processing and verification u/s 195, 197 and 201 of the Income Tax Act, 1961.

2. Transfer Pricing

   This area of operation is manned by various Directorates of Transfer Pricing, and caters to determination of arm's length price of international transactions pertaining to transfer of goods, services, intangibles, etc between two or more Associate Enterprises (AE) under Chapter- X of the Income Tax Act, 1961.

3. Advance Pricing Agreements

   The scheme of Advance Pricing Agreement (APA) under Transfer Pricing Regulations has been introduced in the union budget for 2012 -13. This scheme is an agreement between the CBDT and the taxpayer for determination of Arms Length Price (ALP) or manner for determination of ALP, in relation to an international transaction between the associated enterprises (AEs), in advance.

4. Dispute Resolution Panel (DRP)

   Section 144C of the Income Tax Act, 1961 governs the provisions relating to DRP and defines DRP as a collegiums comprising of three Commissioners of Income Tax constituted by the Central Board of Direct Taxes for this purpose. When the Assessing Officer (AO) proposes by a way of draft assessment order made u/s 144C of the Act to make any variation in the income or loss stated in the return filed by the assessee on the basis of Transfer Pricing adjustment and invites assessee' acceptance or objections to the same. Assessee may communicate his acceptance to the order or may file objection before the DRP against the proposed assessment order. The DRP after giving opportunity of hearing to the assessee, passes suitable order in the case within 9 months.