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 ...
Income Tax : The ruling explains strict compliance requirements for specified domestic transactions, including maintaining detailed documentati...
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 : 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 : The Mumbai ITAT upheld TNMM for Firmenich Aromatics, deleting transfer pricing adjustments on exports and royalties, and allowed a...
Income Tax : Kolkata ITAT rules corporate guarantee is international transaction but limits transfer pricing adjustment to 0.5% for Tega Indust...
Income Tax : ITAT Ahmedabad clarifies corporate guarantees as international transactions, yet upholds Adani Ports' appeal on no arm's length a...
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 ...
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.
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.
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.
The Mumbai ITAT upheld TNMM for Firmenich Aromatics, deleting transfer pricing adjustments on exports and royalties, and allowed an 80G deduction on CSR donations.
Kolkata ITAT rules corporate guarantee is international transaction but limits transfer pricing adjustment to 0.5% for Tega Industries, citing judicial precedent.
ITAT Ahmedabad clarifies corporate guarantees as international transactions, yet upholds Adani Ports’ appeal on no arm’s length adjustment, citing no AE benefit.
