Income Tax : Taxpayers entering specified domestic transactions exceeding prescribed thresholds must maintain transfer pricing documentation, a...
Income Tax : The article explains how multinational digital companies generate substantial revenue from Indian users while shifting profits to ...
Income Tax : Form 46 allows taxpayers to exercise the option for determination of arm’s length price for international or specified domestic ...
Finance : A summary of the UAE Corporate Tax Law's definitions for related parties under Article 35 and the arm's length principle in Articl...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
Income Tax : Notification of Transfer Pricing Rules to incorporate range concept and use of multi-year data to reduce litigation on transfer pr...
Income Tax : ITAT Delhi remanded ALP adjustment issues for fresh FAR analysis of two comparables and reconsideration of working capital adjustm...
Income Tax : The ITAT held that where transactions with the Indian associated enterprise are at arm's length, additional profit attribution to ...
Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
Income Tax : The Chennai ITAT held that transfer pricing benchmarking cannot ignore extraordinary business circumstances arising from the shutd...
Income Tax : Supreme Court dismissed the SLP, affirming that ITAT rightly remanded the case to TPO to reassess ALP of intra-group services, str...
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 : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
Income Tax : Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the ...
ITAT Delhi remanded ALP adjustment issues for fresh FAR analysis of two comparables and reconsideration of working capital adjustment.
The ITAT held that where transactions with the Indian associated enterprise are at arm’s length, additional profit attribution to the alleged permanent establishment is unwarranted. The Tribunal therefore deleted the income attributed by the Assessing Officer.
The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of international transactions. It directed inclusion and exclusion of specific comparables and partly allowed the assessee’s appeal.
Taxpayers entering specified domestic transactions exceeding prescribed thresholds must maintain transfer pricing documentation, as failure to do so can attract penalties of 2% of the transaction value and other compliance consequences.
The article explains how multinational digital companies generate substantial revenue from Indian users while shifting profits to low-tax jurisdictions. Existing transfer pricing rules struggle to capture value created through digital presence and data monetisation.
The Chennai ITAT held that transfer pricing benchmarking cannot ignore extraordinary business circumstances arising from the shutdown of a major customer. The Tribunal upheld deletion of TP adjustment after accepting that sale of goods to the AE was a distress sale triggered by Nokia India’s closure.
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.
Notification 157/2025 sets 1% tolerance for wholesale trading and 3% for all other cases for Arm’s Length Price variation for AY 2025-2026 under the Income-tax Act.
Supreme Court dismissed the SLP, affirming that ITAT rightly remanded the case to TPO to reassess ALP of intra-group services, stressing that Section 92C(3) conditions must be examined before adjustments.
A summary of the UAE Corporate Tax Law’s definitions for related parties under Article 35 and the arm’s length principle in Article 34, including transfer pricing methods.
