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ALP

Latest Articles


Transfer Pricing: Multi-Year ALP Determination in Budget 2025 – FAQs

Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...

February 2, 2025 468 Views 0 comment Print

Finance Bill 2025: Amendment related to Transfer Pricing

Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...

February 1, 2025 858 Views 0 comment Print

Revenue authorities lack jurisdiction to question commercial wisdom of taxpayer

Income Tax : Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cas...

October 19, 2024 774 Views 0 comment Print

Transfer Pricing – Part 2 – Compliance and Assessment Procedures

Income Tax : Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs...

March 28, 2024 4575 Views 0 comment Print

Related Party Transactions: AS 18 vs. Transfer Pricing in India

Corporate Law : Explore intricacies of Related Party Transactions under AS 18 and Transfer Pricing in India. Understand control, influence, disclo...

January 3, 2024 3765 Views 0 comment Print


Latest News


Transfer Pricing Rules to incorporate “range concept” and “use of multi-year data”

Income Tax : Notification of Transfer Pricing Rules to incorporate range concept and use of multi-year data to reduce litigation on transfer pr...

October 20, 2015 1057 Views 0 comment Print


Latest Judiciary


Comparable Selection for Arm’s Length Price Relies on Functional Similarity

Income Tax : Delhi High Court remands Alcatel Lucent's transfer pricing case to ITAT, questioning selection of comparables in ALP determination...

November 3, 2024 432 Views 0 comment Print

High Brand Value, Large-Scale Operations & Lack of Segmented Data are valid Ground for Exclusion in ALP Determination

Income Tax : Delhi High Court judgment on Cadence Design's appeal against the ITAT order regarding transfer pricing comparables. Key findings o...

November 1, 2024 192 Views 0 comment Print

Indian Subsidiary Compensated at ALP Not a Dependent Agent PE: Delhi HC

Income Tax : Delhi HC rules Krones' Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority's appeal....

October 11, 2024 186 Views 0 comment Print

TPO must justify altering the previously accepted position on comparables

Income Tax : Punjab & Haryana High Court rules comparable used in ALP determination must be justified. The court dismisses Revenue's appeal, up...

September 24, 2024 273 Views 0 comment Print

Delhi HC ruling on transfer pricing provisions concerning intra-group services

Income Tax : Read the Delhi High Court judgment on PCIT vs Mercer Consulting India Pvt. Ltd. regarding transfer pricing provisions and intra-gr...

May 8, 2024 618 Views 0 comment Print


Latest Notifications


Deemed Arm’s Length Price for Assessment Year 2023-2024

Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023  regarding deemed arm's length price for assessment year 2023-2024. Le...

June 26, 2023 1716 Views 0 comment Print

Notification on ALP determination in respect of wholesale trading

Income Tax : Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the ...

July 14, 2016 20705 Views 0 comment Print


Latest Posts in ALP

Transfer Pricing: Multi-Year ALP Determination in Budget 2025 – FAQs

February 2, 2025 468 Views 0 comment Print

Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings in transfer pricing for taxpayers.

Finance Bill 2025: Amendment related to Transfer Pricing

February 1, 2025 858 Views 0 comment Print

The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its framework and proposed changes.

Comparable Selection for Arm’s Length Price Relies on Functional Similarity

November 3, 2024 432 Views 0 comment Print

Delhi High Court remands Alcatel Lucent’s transfer pricing case to ITAT, questioning selection of comparables in ALP determination. Detailed review of objections awaited.

High Brand Value, Large-Scale Operations & Lack of Segmented Data are valid Ground for Exclusion in ALP Determination

November 1, 2024 192 Views 0 comment Print

Delhi High Court judgment on Cadence Design’s appeal against the ITAT order regarding transfer pricing comparables. Key findings on ALP determination and comparability.

Revenue authorities lack jurisdiction to question commercial wisdom of taxpayer

October 19, 2024 774 Views 0 comment Print

Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cases, ITAT rulings emphasize.

Indian Subsidiary Compensated at ALP Not a Dependent Agent PE: Delhi HC

October 11, 2024 186 Views 0 comment Print

Delhi HC rules Krones’ Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority’s appeal.

TPO must justify altering the previously accepted position on comparables

September 24, 2024 273 Views 0 comment Print

Punjab & Haryana High Court rules comparable used in ALP determination must be justified. The court dismisses Revenue’s appeal, upholding ITAT’s ruling.

Delhi HC ruling on transfer pricing provisions concerning intra-group services

May 8, 2024 618 Views 0 comment Print

Read the Delhi High Court judgment on PCIT vs Mercer Consulting India Pvt. Ltd. regarding transfer pricing provisions and intra-group services.

Consider Volume Discount & Geographic Price Variation in TP Adjustment: ITAT Ahmedabad

May 8, 2024 366 Views 0 comment Print

Ahmedabad ITAT’s order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. Detailed analysis provided.

Ahmedabad ITAT Clarifies Letter of Credit vs. Bank Guarantee in Transfer Pricing Dispute

May 8, 2024 1050 Views 0 comment Print

In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Corporate Guarantee, resolving disallowance disputes.

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