Income Tax : Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs...
Corporate Law : Explore intricacies of Related Party Transactions under AS 18 and Transfer Pricing in India. Understand control, influence, disclo...
Income Tax : Explore the rules and challenges of Domestic Transfer Pricing (DTP) in India. Learn about legal definitions, threshold limits, app...
Income Tax : Penalties for failing to maintain records of specified domestic transactions. Learn about arm's length pricing & essential documen...
Income Tax : Explore landmark cases like SAP Labs vs. IT Officer, Evalueserve vs. Commissioner, and Softbrands vs. IT. Learn how the law and fa...
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 : Read the Delhi High Court judgment on PCIT vs Mercer Consulting India Pvt. Ltd. regarding transfer pricing provisions and intra-gr...
Income Tax : Ahmedabad ITAT's order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. De...
Income Tax : In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Co...
Income Tax : ITAT considered the justification provided by the assessee, which referenced KITCO and Reuters databases for determining transacti...
Income Tax : In the case of Honda Motorcycle & Scooter India Pvt Ltd vs. ACIT, ITAT Delhi directed the Transfer Pricing Officer (TPO) and Asses...
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 ...
Explore the rules and challenges of Domestic Transfer Pricing (DTP) in India. Learn about legal definitions, threshold limits, applicability, Arm’s Length Price, documentation, issues, and techniques.
Explore Delhi HC judgment in PCIT vs. Fujitsu India Ltd. for AY 2011-14, focusing on Transfer Pricing Method. Analysis of TNMM vs. RPM with key findings. Insights and conclusion provided.
ITAT Mumbai held that Arm’s Length Price (ALP) of guarantee commission was determined at the rate of 0.3523% instead of 1.25%.
Delhi High Court supports ITAT’s verdict on the selection of comparables for determining the Arm’s Length Price of an international transaction. Get insights on PCIT vs Chrys Capital
ITAT that as long as the charges for hourly services provided by appellant were uniform to AEs and third parties, rejection of CUP method was unwarranted.
Penalties for failing to maintain records of specified domestic transactions. Learn about arm’s length pricing & essential document requirements
Explore landmark cases like SAP Labs vs. IT Officer, Evalueserve vs. Commissioner, and Softbrands vs. IT. Learn how the law and facts intersect in transfer pricing disputes.
ITAT Mumbai held that TP adjustment in respect of international transaction of reimbursement of Employee Stock Option Plan (ESOP) Expenses deleted as Arm’s Length Price (ALP) of ESOP expenses cannot be taken as NIL.
ITAT Mumbai held that the determination of Arm’s Length Price (ALP) without applying any methods as prescribed under section 92C(1) of the Income Tax Act by the TPO is not tenable in law.
ITAT Delhi deleted TP adjustment on payment of model fee for export to AEs stating that scope of TPO is limited to determination of arm’s length price and TPO cannot adjudge commercial expediency of a transaction.
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