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 ...
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.
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.
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.
