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 ...
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.
ITAT Delhi directs segment-wise ALP, includes Fiberfox comparable, and rejects notional interest on AE dues for Opterna Technologies, remits Section 68 issue.
Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings in transfer pricing for taxpayers.
The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its framework and proposed changes.
Delhi High Court remands Alcatel Lucent’s transfer pricing case to ITAT, questioning selection of comparables in ALP determination. Detailed review of objections awaited.
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 the business decisions or commercial wisdom of taxpayers in transfer pricing cases, ITAT rulings emphasize.
Delhi HC rules Krones’ Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority’s appeal.
