Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...
Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...
Income Tax : The update outlines revised compliance forms, timelines, and penalties under the new rules. It highlights a structured transition ...
Corporate Law : The issue was identifying the correct transfer pricing method for intercompany transactions. The conclusion holds that TNMM is app...
Income Tax : CBDT signed a record number of APAs to provide clarity on transfer pricing and reduce disputes. The framework ensures advance dete...
CA, CS, CMA : KSCAA urged CBDT to extend due dates for assessees under Section 92E, citing an omission in Circular No. 15/2025 that created inco...
CA, CS, CMA : Chartered Accountants Association, Ahmedabad requests extension of ITR and audit due dates for AY 2025-26 citing compressed timeli...
Income Tax : CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing cla...
Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...
Income Tax : ITAT Delhi held that television channel and content owner companies could not be compared with a content distribution business. Th...
Income Tax : ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earl...
Income Tax : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...
Income Tax : The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in In...
Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...
Income Tax : Notification 157/2025 sets 1% tolerance for wholesale trading and 3% for all other cases for Arm's Length Price variation for AY 2...
Income Tax : CBDT notifies Income Tax (Sixth Amendment) Rules, 2025, introducing safe harbour rules for assessment year 2025-26. Full details o...
Income Tax : CBDT sets 1% tolerance for wholesale trading and 3% for other cases under Section 92C for FY 2024-25. No adverse effects from retr...
Income Tax : Stay informed on the latest Income Tax Rule changes with Notification No. 104/2023 by the Ministry of Finance. Learn about amendme...
Income Tax : Read how CBDT's Notification No. 58/2023 amends Income-tax Rules, extending Safe Harbour rules to AY 2023-24. Insights from Minist...
The Tribunal held that once TNMM is accepted for a set of linked transactions, the TPO cannot separately benchmark Management Fees or treat their ALP as Nil. The adjustment was deleted as the fees were already included in the cost base used for arm’s length analysis.
The Tribunal upheld CIT(A)’s deletion of ₹2.81 crore transfer pricing adjustment, ruling that selected comparables were functionally and financially dissimilar. PSM was maintained as the Most Appropriate Method, ensuring fair benchmarking of international transactions.
Breaks down India’s transfer pricing framework, recent amendments, and judicial trends, highlighting how the arm’s-length principle is applied and what taxpayers must comply with.
Covers the Tribunal’s ruling upholding most TPO-selected comparables while excluding product-owning entities, clarifying how functional similarity drives benchmarking in software distribution.
The ITAT Delhi partly allowed the appeal as the AO/TPO selected a company that failed the turnover filter for transfer pricing. Key takeaway: Transfer pricing adjustments must follow proper comparability filters and FAR analysis.
The ruling explains strict compliance requirements for specified domestic transactions, including maintaining detailed documentation for eight years. It highlights that failure to maintain, report, or furnish accurate information attracts penalties of up to 2% of transaction value.
The Tribunal held that a captive software development service provider cannot be compared with giant IT companies owning IP, diversified services, and global operations. By excluding these functionally dissimilar comparables, the entire ₹10.58 crore TP adjustment was deleted.
ITAT emphasized that taxpayers must substantiate the receipt and benefit of group services, remanding the matter due to inadequate examination by lower authorities.
Explains the step-by-step TP study process and highlights common documentation, data, and benchmarking challenges, along with what the analysis ultimately held regarding verification requirements.
The Tribunal applied long-standing rulings invalidating the intensity and BLT approaches for AMP benchmarking, deleting both substantive and protective adjustments. The decision underscores that such methods lack statutory support.
