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 ...
Under Transfer Pricing regulation, Safe Harbor rules means binding rules laid down under law which mandates income tax authorities to accept the transfer price declared by the assesse, if opted for. Further section 92CB provides methods for determination of arm’s length price.
Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the price at which the international transaction or specified domestic transaction has actually been undertaken does not exceed one percent of the latter in respect of wholesale trading and three percent.of the latter in all other cases
The ITAT Ahmedabad in the case of Gemstone Glass Pvt. Ltd vs. JCIT held that when an associated enterprise is taken as comparable then CUP method cannot be adopted for determining Arm Length Price irrespective of the fact that the associated enterprise taken as comparable is resident or non-resident.
The Finance (No. 2) Act, 2014 proposed to introduce a more streamlined method to compute Arm’s Length Price (ALP) in a situation where more than one price is determined, on adoption of Most Appropriate Method(MAM). The first and second provisos were made redundant for all transactions undertaken on or after 01/04/2014. This was done so as to remove the vagueness that prevailed in the computation of ALP, by way of arithmetic mean.
Notification of Transfer Pricing Rules to incorporate range concept and use of multi-year data to reduce litigation on transfer pricing issues.
In case of M/s. AT & T Global Business Services India Pvt.Ltd. VS. ITO , assessee-company, engaged in business of software development and providing application services to its AE. TPO on basis of mean margin earned by his own set of comparables
Assessee had given the loan to the associate enterprise in U.S.D. and in such a situation when the transaction was in foreign currency, and the transaction was an international transactions, then the transaction would have to be looked upon by applying the commercial principles in regard to international transactions.
Section 139 of the Act provides for due date of filing return of income in case of various categories of persons. In addition to filing of return of income, the assesses who have undertaken international transactions are also required to prepare and file a Transfer Pricing report in Form 3CEB, as per Section 92E of the Act, before the due date of filing of return of income.
