Income Tax : Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cas...
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 : Notification of Transfer Pricing Rules to incorporate range concept and use of multi-year data to reduce litigation on transfer pr...
Income Tax : Delhi High Court remands Alcatel Lucent's transfer pricing case to ITAT, questioning selection of comparables in ALP determination...
Income Tax : Delhi High Court judgment on Cadence Design's appeal against the ITAT order regarding transfer pricing comparables. Key findings o...
Income Tax : Delhi HC rules Krones' Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority's appeal....
Income Tax : Punjab & Haryana High Court rules comparable used in ALP determination must be justified. The court dismisses Revenue's appeal, up...
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 : 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 ...
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.
Read the full text of the Delhi High Court judgment in the CIT vs. Sumitomo Corporation India Pvt Ltd case, concerning Assessment Years 2012-13 and 2013-14. TNMM found suitable for determining ALP for international indenting-transactions.
ITAT Mumbai held that the TPO is not correct in arriving at the ALP as NIL on the ground that the need and benefit test is not satisfied by the assessee without giving any contrary findings with regard to the various documents including the TP study submitted by the assessee.
Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm’s length price for assessment year 2023-2024. Learn about the tolerance range for wholesale trading and other cases in international transactions or specified domestic transactions.
ITAT Bangalore held that if the net profit margin meets the Arm’s length price, then no separate addition needs to be made. Accordingly, TPO directed to delete the adjustment made towards Advertising Marketing Price (AMP) expenses.
Tribunal Decision determining ALP can be challenged on grounds of perversity & non observance of transfer pricing rules in individual cases