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 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 : The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT dat...
Income Tax : Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a singl...
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 ruling emphasizes that once the Transfer Pricing Officer accepts the arm’s length nature of a transaction, the Assessing Officer cannot question its reasonableness. The disallowance was deleted as the interest rate complied with transfer pricing norms and reflected commercial reality.
The Tribunal held that BLT cannot be used for transfer pricing adjustments on AMP expenses. It ruled that no adjustment was warranted based on binding precedents.
The update outlines revised compliance forms, timelines, and penalties under the new rules. It highlights a structured transition from existing provisions to a stricter and more automated compliance framework.
The issue was identifying the correct transfer pricing method for intercompany transactions. The conclusion holds that TNMM is appropriate where one entity performs routine functions with available comparables.
The Tribunal held that the Indian entity was only a distributor and not a technology or content owner. It rejected the Revenue’s attempt to recharacterise the business and apply royalty-based valuation.
This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and streamlined compliance under prescribed conditions.
The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced disclosures and digital integration for transfer pricing compliance.
The new Act reorganises sections, rules, and forms without changing core transfer pricing principles. Taxpayers must adapt to updated references while continuing existing compliance practices.
The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that companies with disproportionately large turnover must be excluded as they distort comparability due to scale advantages.
CBDT signed a record number of APAs to provide clarity on transfer pricing and reduce disputes. The framework ensures advance determination of pricing methods, minimizing litigation and double taxation risks.
