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 Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating such addition in a Section 263 order was held invalid.
The article explains how ESOP taxation spans salary, capital gains, DTAA, and disclosure requirements. It highlights that errors in valuation, reporting, or FTC claims can lead to significant tax exposure.
The article explains that tax authorities often disallow intra-group charges where evidence of actual services is missing. Even correct pricing cannot sustain a claim without proving benefit and delivery. The key takeaway is that documentation is more critical than pricing sophistication.
Explains how Form 49 replaces multiple forms to streamline Safe Harbour compliance and reduce duplication in transfer pricing filings.
The new Form 48 replaces Form 3CEB and mandates reporting of international and domestic transactions. It enhances structured transfer pricing compliance.
Form 46 allows taxpayers to exercise the option for determination of arm’s length price for international or specified domestic transactions for two tax years.
The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham transactions. Notional interest addition was deleted.
The tribunal held that the safe harbour limit applies to valuation determined by the DVO, not just stamp duty value. It ruled in favour of the assessee as the variation was within 10%.
The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitling the assessee to refund.
The issue was whether ALP can be determined without comparable transactions. ITAT held that Rule 10AB mandates comparables, making the TPO’s approach invalid and restricting the adjustment.
