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 ...
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.
ITAT considered the justification provided by the assessee, which referenced KITCO and Reuters databases for determining transaction prices. However, the Transfer Pricing Officer (TPO) argued that the London Bullion Market Association (LBMA) should be the primary source for estimating bullion trading prices.
In the case of Honda Motorcycle & Scooter India Pvt Ltd vs. ACIT, ITAT Delhi directed the Transfer Pricing Officer (TPO) and Assessing Officer (AO) to delete the adjustment made on account of the arm’s length price (ALP) of export commission payment.
Delhi High Court rules AO can’t deviate from Transfer Pricing Officer’s determined Arm’s Length Price (ALP) in international transactions, upholding assessee’s writ petition.
Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs, and penalties for non-compliance.
Explore the ITAT Delhi ruling on the eligibility of management service fees paid to non-resident AEs under section 37(1) of the Income Tax Act in the case of Iris Worldwide Integrated Marketing Pvt. Ltd vs. DCIT.
Explore the judgment in Bombardier Transportation India Pvt. Ltd. Vs DCIT by Delhi High Court. The court remits the matter for determining the Arm’s Length Price (ALP) method.
Explore intricacies of Related Party Transactions under AS 18 and Transfer Pricing in India. Understand control, influence, disclosure requirements and how arm’s length principle is applied.
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.
